Scope of policy
The Takumi mobile application software (App) available from the Apple App Store (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device); and
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Act 1998, the data controller is Takumi International Limited of 1 St Katharines Way, London, E1W 1UN.
Information we may collect from you
We may collect and process the following data about you:
Information you give us (Submitted information): You may give us information about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by e-mail or chat). This includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, share data via an App's social media functions, enter a competition, promotion or survey and when you report a problem with an App, our Services, or any of our Sites. The information you give us may include your name, address, e-mail address, phone number, the Device's phone number, age, username, password and other registration information, financial and credit card information, personal description and photograph.
Information we collect about you and your device (Collected Information). Each time you visit one of our Sites or use the App we may automatically collect the following information:
Your Internet Protocol Addresses, internet service provider, referring/exit pages and clickstream data;
technical information, including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting;
Information stored on your Device, including contact information, friends lists, login information, photos, videos or other digital content and check ins;
details of your use of the App or your visits to any of our Sites including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Location information. We may also use GPS technology or other technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by emailing us at email@example.com
Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
Unique application numbers: when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
Uses we make of the information
We use information held about you in the following ways:
Submitted Information: to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us; to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about; to provide you with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, we will contact you by electronic means only if you have consented to this; to notify you about changes to our service; to ensure that content from the App and our Sites is presented in the most effective manner for you and for your Device.
Collected Information: to administer the App and our Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to improve the App and our Sites to ensure that content is presented in the most effective manner for you and for your Device; to allow you to participate in interactive features of the App and our Services, when you choose to do so; as part of our efforts to keep the App and our Sites safe and secure; to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; to make suggestions and recommendations to you and other users of the App and our Sites about goods or services that may interest you or them; to analyse trends; to track users' movements around the App and our Sites.
Location information: to serve you with information about Brand Owner's campaigns which are more likely to be of interest to you (for example, campaigns which apply to your geographical location).
Third Party Information: we may combine this information with other information we hold about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
Unique application numbers: to ensure that content is presented in the most effective manner for your Device; to maintain, protect and improve the App, the Services and the Services Sites; to notify the you about changes to the App or any of the Services.
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
We share aggregated demographic information about our user base with our agents, including agencies or third-party vendors used to aggregate demographic information, provide marketing analysis and consult on advertising strategies. This information does not identify individual users. We do not link this aggregate user data with personally-identifying information.
We do not rent or sell email addresses, postal addresses or telephone contact information to third parties, or otherwise share any personally-identifying information we collect, with any third parties.
However, we may share your personal information with the Brand Owners and their agents for the purposes set out below.
Any information we track in this manner is anonymous, limited to usage and volume statistics and is used to provide insight into the effectiveness of our online marketing initiatives and strategies.
Uses the Brand Owners may make of the information
The Brand Owners will use your information to: offer you the chance to participate in their campaigns; carry out their obligations to you in respect of each campaign in which you participate; post the images you submit to them as part of their campaigns on their social media accounts for public view; and to communicate with you via the App's messaging service.
The Brand Owners may use your information to provide you with information about the Brand Owner's campaigns which the Brand Owner believes are more likely to be of interest to you (for example, campaigns which apply to your geographical location).
The Brand Owners may engage third party agents for the above purposes. In those circumstances, your personal information will be used by the agent for the above purposes.
Disclosure of your information
We may disclose some or all of the data we hold on you to the following third parties:
Our cloud service provider for the purposes of them providing us with cloud storage services; and
Our third party payment processor for the purposes of processing payments due to you as a result of your participation in one of the Brand Owner's campaigns.
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We may disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If Takumi International Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
In order to:
protect the rights, property or safety of Takumi International Limited, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store your personal data
All information you provide to us is stored on our or our cloud service provider's secure servers.
Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App or our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the App or our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We may collect and store personal data on your Device using application data caches and browser web storage (including HTML 5) and other technology.
Certain Services include social networking, chat room, messaging services or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users or by the Brand Owner.
Use of your personal information by Instagram and the Brand Owners
We do not offer the App or any Services to children under 16 years of age. Users of the App and our Services are asked to confirm their date of birth as part of the registration process. Any user who indicates that they are under 16 years of age will not be able to use the App or our Services. If you believe that your child has provided a false date of birth to use the App or our Services, please let us know by contacting us at firstname.lastname@example.org.
If you are not happy with the ways in which we process your personal information, please contact us at email@example.com so we can resolve the issue for you.
Third party sites
The App or our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
Access to information
The Data Protection Act 1998 gives you the right to access information held about you. Your right of access can be exercised in accordance with that Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you. If you would like to access the information we hold on you, please contact us at firstname.lastname@example.org.
Effective: May 30, 2016