Privacy policy

Effective Date: February 6, 2026
Last Updated: February 28, 2026

This Privacy Policy explains how COMPASS Learning Corporation ("we," "us," or "our"), collects, uses, discloses, and protects your personal information when you visit our website, place an order, or interact with our customer service for KINUJO brand hair care and beauty devices, hair dryers, straighteners, and related accessories.

We are committed to complying with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and all issuances of the National Privacy Commission (NPC).

1.  CONTROLLER / PROCESSOR ROLES

Personal Information Controller (PIC): COMPASS Learning Corporation is the PIC for all personal information collected through KINUJO Philippines. We determine the purposes and means of processing your personal data.

Personal Information Processors (PIPs): We engage third-party processors who handle personal information on our behalf, including:

  • Shopify (website hosting and e-commerce platform)
  • Payment Gateways: PayPal,
  • Courier Services: LBC, J&T Express, Lalamove, GrabExpress
  • Email/SMS Services: For order and warranty notifications
  • Customer Support Tools: For managing inquiries and warranty claims

2. INFORMATION WE COLLECT

2.1 Personal Information You Provide

We may collect the following categories of personal information directly from you:

  • Contact Information: Full name, email address, phone number, billing address, shipping address
  • Account Information: Username, password (encrypted), account preferences
  • Payment Information: Credit/debit card details, e-wallet information, billing information (processed securely by our payment gateways)
  • Order Information: Purchase history, product preferences, delivery instructions
  • Product Warranty and After-Sales Information: Product serial numbers, purchase date, proof of purchase, warranty registration details, repair or replacement requests
  • Communications: Messages sent through contact forms, customer service emails, chat logs, feedback, and product reviews


2.2 Information Collected Automatically

When you visit our website, we may automatically collect:

  • Device Information: IP address, browser type, operating system, device identifiers
  • Usage Data: Pages viewed, time spent on site, clickstream data, referral sources
  • Location Data: Approximate geographic location based on IP address (for shipping estimates and regional promotions)
  • Cookies and Tracking Technologies: As described in Section 11 below

3. LAWFUL BASES FOR PROCESSING PERSONAL INFORMATION

We process your personal information on the following lawful bases under the DPA:

  • Contract / Order Processing: To fulfill your order, deliver products, process payments, and provide warranty and after-sales support
  • Compliance with Legal Obligations: To comply with tax laws (BIR regulations), consumer protection laws (RA 7394), and other legal requirements
  • Legitimate Interests: To prevent fraud, improve our services, analyze website usage, and ensure secure transactions—provided these interests do not override your fundamental rights
  • Consent: For marketing communications, newsletter subscriptions, and optional data uses (you may withdraw consent at any time)

4. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

  1. Order Processing and Fulfillment: To process, confirm, and deliver your orders.
  2. Customer Service: To respond to inquiries, resolve complaints, and provide product support.
  3. Warranty and After-Sales Support: To register warranties, process repair or replacement requests, track product performance, and provide technical assistance for KINUJO products manufactured for the Philippine market (Model: KHPH302). Please note that parallel import products (models other than KHPH302) are not eligible for warranty registration or warranty-related support.
  4. Account Management: To create and manage your user account.
  5. Marketing and Promotions: To send promotional emails, product updates, and exclusive offers (only with your consent).
  6. Compliance and Legal: To comply with Philippine tax, consumer protection, and data privacy laws.
  7. Security and Fraud Prevention: To detect, prevent, and respond to fraudulent transactions or security incidents.
  8. Analytics and Improvement: To understand customer preferences, improve our website and services, and optimize the user experience.

5. DISCLOSURE AND SHARING OF PERSONAL INFORMATION

We do not sell your personal information. We may share your personal information with:

  1. Service Providers (Personal Information Processors): Third-party vendors who assist us with website operations, payment processing, shipping, and customer support
  2. Payment Processors: To facilitate secure transactions
  3. Shipping and Logistics Partners: To deliver your orders
  4. Government Authorities: When required by law (e.g., BIR for tax purposes, NPC for data privacy compliance, DTI for business registration)
  5. Legal Compliance: To comply with legal obligations, enforce our Terms and Conditions, and protect our rights
  6. Business Transfers: In connection with a merger, acquisition, or sale of assets (you will be notified beforehand)

All third parties are required to comply with the DPA and maintain the confidentiality and security of your personal information.

6. INTERNATIONAL TRANSFERS TO HEAD OFFICE - KINUJO CO., LTD. JAPAN

We may transfer your personal information to KINUJO Co., Ltd., our parent company in Japan, for the following purposes:

  • Warranty Processing: To validate warranties, coordinate product repairs or replacements, and provide after-sales support for KINUJO-branded products
  • Product Quality Assurance: To analyze product performance, track defects, and improve product quality
  • Customer Feedback and Support: To handle escalated customer service inquiries, process warranty claims, and ensure consistent global support standards

Such transfers will be conducted in compliance with Section 26 of the DPA and NPC Circular No. 16-03 on the Security of Personal Data in Government. We ensure that KINUJO Co., Ltd. provides adequate safeguards, including:

  • Contractual Clauses: Data processing agreements with security and confidentiality obligations
  • Data Protection Standards: KINUJO Co., Ltd. adheres to data protection practices comparable to those required by the DPA
  • Limited Purpose: Data is shared only for the purposes stated above and is not used for unauthorized purposes
  • Your Rights: You retain all rights under the DPA, including the right to access, correct, and delete your personal information

7. DATA RETENTION

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law:

  • Order and Transaction Records: 5 years (in compliance with BIR tax recordkeeping requirements).
  • Warranty Records: For the duration of the warranty period plus 2 additional years for potential claims (applicable to Philippine-market products, Model: KHPH302 only). For parallel import products, purchase records are retained for 2 years from the date of purchase.
  • Marketing Consents: Until you withdraw consent.
  • Account Information: Until you request account deletion, or after 3 years of inactivity.
  • Legal and Compliance Records: As required by applicable Philippine laws.

After the retention period expires, we will securely delete or anonymize your personal information.

8. DATA SECURITY

We implement reasonable organizational, physical, and technical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

  • Encryption: Secure Socket Layer (SSL) encryption for payment and sensitive data
  • Access Controls: Role-based access restrictions for employees and third parties
  • Regular Audits: Periodic security assessments and vulnerability testing
  • Third-Party Security: All processors (Shopify, payment gateways, couriers) comply with industry-standard security protocols
  • Incident Response: Procedures to detect, respond to, and report data breaches in compliance with NPC regulations

While we strive to protect your personal information, no system is 100% secure. You are responsible for maintaining the confidentiality of your account credentials.

9. YOUR RIGHTS AS A DATA SUBJECT

Under the DPA, you have the following rights:

  1. Right to Be Informed: You have the right to know how we collect, use, and process your personal information
  2. Right to Access: You may request a copy of your personal information we hold
  3. Right to Rectification: You may request corrections to inaccurate or incomplete personal information
  4. Right to Erasure (Right to be Forgotten): You may request deletion of your personal information, subject to legal retention requirements
  5. Right to Object: You may object to the processing of your personal information for direct marketing or other purposes
  6. Right to Data Portability: You may request a copy of your personal information in a structured, commonly used, and machine-readable format
  7. Right to Lodge a Complaint: You may file a complaint with the National Privacy Commission if you believe your data privacy rights have been violated

To exercise your rights, please contact us.

10. MARKETING AND COMMUNICATIONS

With your consent, we may send you promotional emails, newsletters, and product updates. You may opt out at any time by:

  • Clicking the "Unsubscribe" link in any marketing email
  • Contacting us at "kinujo[at]compass.style"
  • Updating your account preferences

Even after opting out, you will still receive transactional emails (order confirmations, shipping updates, warranty notifications) necessary to fulfill our contractual obligations.

11. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to enhance your browsing experience and collect usage data:

  • Essential Cookies: Required for website functionality (e.g., shopping cart, login sessions)
  • Analytics Cookies: To track website traffic and user behavior (e.g., Google Analytics)
  • Marketing Cookies: To display targeted advertisements and measure campaign effectiveness (if applicable)

You may manage cookie preferences through your browser settings. Disabling certain cookies may affect website functionality.

12. THIRD-PARTY LINKS

Our website may contain links to third-party websites (e.g., social media platforms, payment gateways). We are not responsible for the privacy practices of these external sites. Please review their privacy policies before providing personal information.

13. USER REVIEWS AND GENERATED CONTENT

If you submit product reviews, testimonials, or other content on our website:

  • Your submitted content (including your name, if provided) may be publicly displayed on our website, social media channels (e.g., Facebook, Instagram), or marketing materials
  • By submitting content, you grant us a non-exclusive, royalty-free, perpetual license to use, reproduce, modify, and display your content for promotional purposes
  • We may share your reviews and testimonials with KINUJO Co., Ltd. (Japan) for global marketing and product improvement purposes
  • You retain ownership of your content but agree not to submit content that violates third-party rights, contains offensive material, or is misleading
  • You may request removal of your content by contacting us, though we reserve the right to retain it for legal or archival purposes if necessary"

14. AGE RESTRICTION

Our website and services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If we discover that we have inadvertently collected information from a person under 18, we will promptly delete it. Parents or guardians who believe their child has provided personal information should contact us.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by:

  • Posting a notice on our website
  • Sending an email to registered users (if applicable)
  • Updating the "Last Updated" date at the top of this Privacy Policy

Your continued use of our website after changes are posted constitutes acceptance of the updated Privacy Policy.

16. NATIONAL PRIVACY COMMISSION CONTACT INFORMATION

If you have concerns about how we handle your personal information, you may file a complaint with the National Privacy Commission:

Website: https://www.privacy.gov.ph

Email: info@privacy.gov.ph

Hotline: (+632) 8234-2228

17. GOVERNING LAW

This Privacy Policy is governed by and construed in accordance with the laws of the Republic of the Philippines, including:

  • Republic Act No. 10173 (Data Privacy Act of 2012)
  • Republic Act No. 7394 (Consumer Act of the Philippines)
  • Republic Act No. 8792 (E-Commerce Act)
  • All relevant issuances of the National Privacy Commission

Any disputes arising from this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of the Philippines.

18. CONTACT INFORMATION

For questions, requests, or concerns regarding this Privacy Policy or our data practices, please contact us:

Company Name: COMPASS Learning Corporation

Email: kinujo[at]compass.style

Address: Unit 2J, The Grand Hamptons Tower 2, 1st Avenue corner 31st Street, BGC, Taguig City