Takumi International Limited is committed to protecting and respecting your privacy.
Takumi International Ltd operates the www.takumi.com website and the Takumi Mobile application (hereinafter referred to as the “Service”).
The key feature of the Takumi mobile application (App) is that it allows you to receive payment from certain brand owners (Brand Owners) for participating in the Brand Owner’s campaigns and posting images on your Instagram account.
- The Takumi mobile application (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 page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
Service means the www.takumi.com website and the Takumi mobile application (App) operated by Takumi International Ltd
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small files stored on your device (computer or mobile device).
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Brand Owner is a Brand or Agency which has assigned Takumi to manage their influencer marketing campaigns.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- 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. If you turn off location services for the Takumi App, we may still use your IP address to determine location (country).
- 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.
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
Use of Data
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.
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.
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
Takumi International Ltd may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- For payment processing purposes
- To comply with the law
Retention of Data
The influencer data stored on the Takumi platform servers is removed upon user request, which can be accomplished from within the app settings screen. If the user has not participated in any Takumi campaigns, the data is removed after a 24 hour cancellation window. If a user has participated in campaigns, we retain his or her data until 6 years have passed since the last participation, as part of our financial records and to fulfil our duties for government reporting.
If not specifically requested, we retain data on our servers as it is required for the app and service to function, but no collection, updating or processing of the user data takes place during this time.
Takumi International Ltd will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside the EEA and choose to provide information to us, please note that we transfer the data, including Personal Data, to Ireland and process it there.
Disclosure of Data
To provide our basic service
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.
Disclosure for Law Enforcement
Under certain circumstances, Takumi International Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Takumi International Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Takumi International Ltd
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Use of your personal information by Instagram and the Brand Owners
We do not offer the App or any Services to children under 18 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 18 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.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Takumi International Ltd aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at email@example.com.
In certain circumstances, you have the following data protection rights:
- The right to access, update or delete the information we have on you. You can access and update certain personal information in the Takumi mobile application. You can also contact us at firstname.lastname@example.org if you wish get access to all of the personal data we hold on your account.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Takumi International Ltd relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
TAKUMI’s use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.
Facebook’s Graph API
We get basic profile information, post information and insights from Facebook’s Graph API. We use this data to match you with appropriate campaign opportunities, evaluate campaign submissions and carry out our core Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Mixpanel is provided by Mixpanel Inc.
You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/
Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Effective: Jan 30, 2020