Privacy Notice: Kakuto Admin and Calendar

This notice explains how personal data is handled in the Kakuto apps that gym owners, staff and coaches use to run their gym:

• Kakuto Admin at admin.kakuto.io
• Kakuto Calendar at calendar.kakuto.io

It covers the data of the people who sign in to these apps, and the data about members, coaches and others that a gym manages in them. It does not cover the kakuto.io website, which has its own privacy policy, or the members’ app, which has its own privacy notice.

Who is responsible

Kakuto is run by Kakuto Technology GK (“Kakuto”, “we”, “us”).

Your gym decides what happens to its data. When a gym uses Kakuto to manage its members, classes, payments, coaches and messages, the gym is the controller of that data and we process it on the gym’s behalf, following its instructions. If you are a member, coach or staff member of a gym and want to see, correct or delete your data, please ask your gym first. We will help the gym answer you.

We are responsible for running the service. We are the controller for the data we need to run Kakuto itself: sign-in and security records, support requests sent to the Kakuto team, and records of how much the AI assistant is used.

To ask anything about this notice, email info@kakuto.io.

Where your data is kept

The records Kakuto keeps for these apps are stored on Amazon Web Services (AWS) in its London region (eu-west-2), in the United Kingdom. That includes the databases, files, backups and logs. AI processing is described separately below. Each gym’s data is kept separately from every other gym’s.

There are a few exceptions, each explained below:

• Emails we send for the apps (such as mass emails and invoices) go out through AWS’s email service in Ireland, in the EU.
• Where a gym enables enterprise AI features, requests are processed within the EU through Amazon Bedrock or sent to OpenAI under the configuration described in Enterprise AI features.
• The app’s own code (not your data) is delivered through AWS’s worldwide content network, so pages load quickly wherever you are.
• Some features send data to the service providers listed under Who we share data with, such as Stripe for payments and Meta for WhatsApp.

What Kakuto Admin collects

What a person can see and do in Kakuto Admin depends on the roles the gym gives them. A coach, for example, does not see the gym’s finances.

Your account

• your email address, which is how you sign in
• your name, nickname, telephone number, date of birth and gender, if you add them to your profile
• your profile photo, if you add one
• the gyms you belong to and the roles each gym gives you

Sign-in is handled by Amazon Cognito. Your password is checked by Cognito and we never see it.

Members and classes

For each member, the gym can keep:

• name, email address, telephone number, date of birth, gender and profile photo
• an emergency contact’s name and telephone number
• the family members a parent signs up and pays for, including children’s names and dates of birth
• memberships, plans and their history
• class bookings, check-ins and attendance
• progress such as grades, belts and Training Journey rewards

Member map

The Member Map shows where a gym’s paying members live, so the gym can plan its locations. Once a month, members’ postal addresses from their payment details are turned into map coordinates using Google’s Geocoding service. The map itself is drawn by Google Maps, which loads from Google in your browser.

Payments and finance

• Subscriptions and payments. Card payments are taken by Stripe and Direct Debits by GoCardless. Kakuto stores the member’s plans, amounts, payment dates and statuses, failed payments and refunds, and the billing address the member gave. Card numbers and bank account details stay with Stripe and GoCardless. Kakuto only receives the last few digits, so staff can tell accounts apart.
• Income. Revenue figures and reports, worked out from the payments above.
• Invoices. Coaches invoice the gym through Kakuto. An invoice holds the coach’s name, email address, postal address and bank details (bank name, account number and sort code), and the classes or work it charges for. The PDF invoice is emailed to the gym’s finance contacts.
• Coach Pay. Where a gym turns it on, it can import the payments it made to coaches from its own accounting software (payee name, date and amount) and compare them with the coaches’ invoices.

Messages and communication

• WhatsApp. Gyms can message members through the WhatsApp Business Platform, run by Meta. Kakuto keeps the telephone numbers, names, messages and images of those conversations. If the gym turns on automatic replies, an AI assistant answers routine questions using the configuration described in Enterprise AI features.
• Announcements and votes. Notices and polls the gym sends to members, and members’ votes. Members are told about them by app notifications, which are delivered by Google Firebase Cloud Messaging and, on iPhones, Apple’s push service. These carry only the notification’s own text.
• Mass email. Emails the gym sends to a chosen group of members: the recipients’ email addresses, the message, and whether each one was delivered.
• Gym inbox. If a gym connects its own email inbox, Kakuto reads the gym’s mail from the last 14 days (the gym can choose up to 60), shows it to the staff allowed to see it, and keeps a copy for that period only. An AI model that we run inside our AWS London environment sorts each email into a category and estimates whether it needs a reply and how urgent it is. Replies are sent from the gym’s own mail server, and Kakuto keeps a record of each reply. Attachments are not downloaded; only their names are shown.
• Support. Questions members send to their gym, and requests the gym sends to the Kakuto team, with the conversation that follows.

Enterprise AI features

Some gym owners subscribe to Kakuto’s enterprise tier, which supports optional AI features. Where the gym enables these features, messages and relevant gym records, including personal data, may be processed to answer questions or carry out tasks on the gym’s behalf.

Depending on the gym’s configuration, AI requests are processed using one of the following arrangements:

• Amazon Bedrock in the EU. AI processing takes place through the Amazon Bedrock runtime in AWS regions within the European Union. The data submitted for AI processing remains within the EU and is not used to train AI models.
• OpenAI commercial API. AI requests are sent to an OpenAI API endpoint under a commercial agreement with Zero Data Retention enabled. OpenAI does not retain the content of those requests or the responses after processing, and does not use that data to train AI models.

These protections apply to processing by the AI provider. They do not change how Kakuto stores the gym’s records or any conversations described in this notice. You can ask your gym which configuration applies.

Staff can ask the assistant (Chat with agent) to look things up or do tasks in Kakuto Admin. It acts as the person using it: it can only see and change what that person could see and change themselves.

We keep each conversation (your messages, the assistant’s replies and the data it looked up) so you can come back to it. Each person sees only their own conversations. We also record how much each person and gym uses the assistant, to apply usage limits. Neither Kakuto nor the configured AI provider uses this data to train AI models.

The AI features in Kakuto help staff; they do not make decisions about anyone on their own. A person at the gym always decides what to do.

Other records

• Wiki. Pages the gym’s staff write, with every earlier version and who saved it.
• Moderation. Reports members make about posts in the members’ app, the reported post, and what the gym decided.
• Gym settings and user management. The gym’s details, its staff’s email addresses and roles, and the rates it pays each coach.
• Activity records. Changes such as wiki edits and email replies record who made them and when.

What Kakuto Calendar collects

Kakuto Calendar uses the same Kakuto sign-in as Kakuto Admin. It keeps:

• your email address, name, language and time zone
• the calendars you create, their names, colours and icons
• events: their title, description, location, times and how they repeat
• teams, the email addresses of the people you invite to them, and whether each invitation was accepted
• who can see or edit each calendar
• sign-ups to events, showing who signed up to which class or session

Public links. If you make a calendar public, anyone with its link can read its events, including in other calendar apps that subscribe to it. Turning the link off stops this.

Cookies and browser storage

Neither app uses analytics or advertising cookies. They keep only what they need in your browser’s storage:

The Kakuto sign-in page, run by Amazon Cognito, sets cookies that are needed for signing in. When you open the Member Map, Google Maps may set its own cookies, and Google receives your IP address and browser details to load the map.

You can clear all of this at any time from your browser. You will then need to sign in again.

Server logs

When you use the apps, our servers record your IP address, the time and the request you made. We use these to run the service, keep it secure and fix faults. Logs are kept in AWS London.

Why we use the data, and the lawful basis

On the gym’s behalf. We use the data a gym manages only to provide the features above to that gym, under our contract with it. The gym is responsible for having a lawful basis for its own use, for example its membership contracts with its members.

For our own purposes. We use sign-in records, logs, support requests and assistant usage to provide the service, keep it secure, answer support requests and apply usage limits. The basis is our contract with the gym and our legitimate interest in running a secure, reliable service. Where the law requires it, the basis is a legal obligation.

We do not sell personal data, use it for advertising, or use it to train AI models.

Who we share data with

We share data only with the service providers that run parts of the apps, under contracts that require them to protect it, and only as needed for the features a gym uses:

• Amazon Web Services provides storage, sign-in (Amazon Cognito), email sending (Amazon SES) and, where configured, AI processing (Amazon Bedrock).
• OpenAI processes AI requests where the gym’s enterprise AI configuration uses its commercial API, with Zero Data Retention and no use of the data for model training.
• Stripe and GoCardless take card and Direct Debit payments.
• Meta (WhatsApp Business Platform) delivers WhatsApp messages.
• Google provides the Member Map (Google Maps and Geocoding) and app notifications (Firebase Cloud Messaging).
• Apple delivers app notifications to iPhones.
• The gym’s own email provider, for gyms that connect their inbox. The gym chooses this provider.

People at the gym see data according to the roles the gym gives them. The Kakuto team accesses a gym’s data only to provide support, fix faults or when the law requires it. We may also disclose data where the law requires it.

International transfers

Data stored by Kakuto stays in the UK, apart from the EU processing described in Where your data is kept. The UK recognises the EU as giving adequate protection.

Stripe, GoCardless, Meta, Google and Apple may process data outside the UK, including in the United States. Where they do, they protect it with safeguards the UK recognises, such as the UK Extension to the EU-US Data Privacy Framework or the UK’s International Data Transfer Addendum to the standard contractual clauses.

OpenAI may process AI requests outside the UK and the EU, depending on the configured endpoint. Where this involves an international transfer of personal data, we use the safeguards required by applicable data protection law. The EU-only processing arrangement applies to the Amazon Bedrock configuration described in Enterprise AI features.

Keeping data safe

• All connections to the apps use encryption (HTTPS).
• Data is encrypted when stored. Secrets such as mailbox passwords are also sealed with keys held in AWS Key Management Service.
• Each gym’s data is separate, and access within a gym is limited by role.
• The AI assistant uses the signed-in person’s own permissions, and its access is removed when each answer is finished.

How long we keep data

• Gym data is kept while the gym uses Kakuto and needs it. A gym can delete records, or ask us to. When a gym stops using Kakuto, we delete or return its data as it instructs, unless the law requires us to keep some of it (for example financial records).
• Gym inbox mail is kept only for the period the gym chooses (14 days unless it chooses otherwise, and never more than 60).
• Backups of Kakuto Calendar can restore data from up to 35 days ago, so deleted data can remain in backups for up to 35 days.
• Our own records (logs, support requests and assistant usage) are kept only as long as we need them for the purposes above.

Your rights

Under the UK GDPR (and the EU GDPR, if you are in the EU), you have the right to:

• get a copy of your personal data
• have inaccurate data corrected
• have your data deleted
• restrict or object to how it is used
• receive data you gave in a portable format

If your data is held by a gym (you are one of its members, coaches or staff), contact the gym first, because it decides what happens to that data. For anything about your Kakuto sign-in or our own records, email info@kakuto.io. We reply within one month.

If you are unhappy with how your data has been handled, please tell us or your gym first. You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk, or to the data protection authority in your country.

Children

Kakuto Admin and Kakuto Calendar are for adults who run or work at a gym. Gyms may keep data about children who train with them, given by a parent or guardian, such as a child’s name and date of birth. The gym is responsible for that data, and only staff whose roles allow it can see it.

Changes to this notice

If we change how these apps use personal data, we will update this page and the date at the top.