Privacy & Cookies Policy


Current: 25 May 2018

This privacy and cookies (“policy”) applies to the processing of personal data by Kotokami LLC and its affiliates, including any subsidiary or parent companies, and their series (collectively, “we,” “us,” or “our”), in connection with the use of our website,, including the use of contact forms, comment forms, sign-up forms, registration forms, mailing list subscription forms and other forms (“Website”), by any individual (“you” or “you”).


This Website is not directed at children, and we do not knowingly collect personal data relating to anyone under the age of 16. Persons over the age of 16 but under the age of 18 should ask their parents before using our website or sending personal data over our website. If a parent or guardian becomes aware that his or her child has provided us with personal data without parental consent, he or she should contact us as described in the section titled “Your Legal Rights” below. If we become aware that a child under 16 has provided us with personal data, we will delete such information from our records.


The object and purpose of this policy is to give you information about how we collect and process your personal data. It is important that you read this policy together with any other notices or policies we may provide at specific times when we are collecting or processing your personal data, so that you are fully aware of how and why we are using your personal data. This policy supplements other notices and policies concerning your personal data, and is not intended to supersede them.


It is important for that your personal data is current and accurate in our records. Please informed us if your personal data changes during your relationship with us. If you wish to update your personal data, please contact us at


This Website may contain links and inline frames (“iframes”) to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, are not responsible for their privacy policies, and cannot guarantee they can or will safeguard your personal data or that they have not been compromised.

The internet can be a scary place. When you follow a link to a third-party website, or enable iframes in your browser, you do so at your own risk. You are strongly encouraged to read the privacy policy of all websites you use.

This Website contains affiliate links. When you click on an affiliate link and make a purchase, we may receive some form of compensation in return. This does not increase your cost in any way. Your purchase will help us run this Website, at no additional cost to you.

Amazon: We are a participant in the Amazon Services LLC Associates Program, an affiliate advertising program designed to provide a means for us to earn fees by linking to and affiliated sites.


Personal data is any information about an individual from which that person can be identified. When information is removed such that an individual cannot be identified, it is anonymous data and not personal data.

We may collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not legally considered personal data because this data does not directly or indirectly reveal your identity. For example, information about how you use this Website may be aggregated to let us know what percentage of Website users are using a specific Website feature. However, if we combine or connect aggregated data with your personal data in such a manner that you can be directly or indirectly identified, we treat the combined data as personal data which will be used in accordance with this policy.

We do not collect any sensitive personal data which is used to uniquely identify you through this Website, including details related to your health, religious or philosophical beliefs, sex life, sexual orientation, or biometric information. relating to your health, religious or philosophical beliefs, or biometric information.

We may collect, use, store and transfer different kinds of personal data about you. We have grouped together the following categories of personal data to explain how this type of information is used by us. These terms are used throughout this policy:

  • “Contact Data”: including your work and home addresses, email addresses and telephone numbers.
  • “Identity Data”: including your first name, last name, username or similar identifier, and title.
  • “Marketing and Communications Data”: including your marketing and communication preferences. We may also track when you have receive and read marketing communications from us. This lets us improve our marketing services, provide you with more relevant information and improve the quality of our marketing materials.
  • “Profile Data”: including information collected progressively when you visit our Website, including the pages pages you visit, actions you take, patterns of page visits, information from forms you fill in and the website you visited from.
  • “Technical Data”: includes information collected when you access our Website, your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you are using.
  • “Usage Data”: information about how you use our Website.


Sometimes we need to collect personal data by law or under the terms of a contract or prospective with you. If you do not provide that data or let us use it, we may be unable to perform the contract we have, or enter into the contract, with you. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.


We use different methods to collect personal data from and about you, including through the channels set out below.

  • Direct interactions: You give us your Contact Data, Identity Data, Technical Data and Profile Data directly, for example, when you: register for a seminar, webinar or event; submit a contact form on our Website; subscribe to our newsletter or to receive our publications; request marketing to be sent to you; enter a survey; or give us some feedback, such as by commenting on our blog or leaving a review.
  • Automated technologies or interactions: We receive Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see the section titled “How We Use Cookies” for further details of the information collected.
  • Third parties or publicly available sources: We receive Technical Data from analytics providers such as Google.


We will only process or use your personal data when we are legally allowed to, that is, when we have a legal basis for processing. When you use our Website we will use your personal data in the following circumstances:

  • “Performance of a contract”: where we need to perform a contract which we are about to enter into or have entered into with you as a party or to take steps at your request before entering into such a contract.
  • “Legal or regulatory obligation”: where we need to comply with a legal or regulatory obligation that we are subject to, such as those related to international sanctions and anti-money laundering.
  • “Legitimate interests”: where necessary for our interests (or those of a third party), provided that your fundamental rights do not override such interests. This can mean, for instance, that it is in our interest, to monitor how you are using our Website to ensure that the security of our Website or systems is maintained, or to be able to continue providing free information. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests
  • “Consent”: Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email.

We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).


Cookies are text files containing small amounts of information that are downloaded to your device when you visit a website. Cookies are sent back to the originating website on each subsequent visit, or to another website that recognizes the cookie. Cookies are useful because they allow a website to recognize a user’s device, preferences and generally help to improve your online experience. You can learn more about cookies at:

The cookies we put on your device and their purposes are as follows:

  • Essential Cookies: these cookies are necessary for the Website to function properly.
  • Performance Cookies: these cookies collect information about how visitors to the Website use it. These cookies do not collect personal data. All information collected by these cookies is anonymous and only used to improve how the Website works.
  • Analytics Cookies: these cookies help us to understand and analyze visitor information to the Website, examples of information include the source and amount of traffic to the Website, how the Website is being used and new visitor numbers.
  • Functionality Cookies: these cookies allow the Website to remember the choices you have made. They make your user experience more convenient and also allows the Website to deliver enhanced, customized and personal features to you. Some of these cookies may be set by third-parties.
  • Advertising or Targeting Cookies: these cookies may be set by third-parties to facilitate the delivery of targeted advertising to you, including through the delivery of interest-based advertising and online-behavioral advertising, when you visit other Websites.
  • Social Media Cookies: these cookies may be set by third-parties to facilitate interaction between your social media, such as facebook, and this Website.

Please be advised that the Website allows third-parties to download cookies to your device. Third-party cookies are not under our control, and this policy does not cover their use. Please refer to the privacy policies of the relevant third-parties.

By using our Website, you agree that we can place these types of cookies on your device. If you want to restrict or block any of the above cookies, you should do this through the web browser settings for each browser you use and on each device you use to access the internet. Please be aware that some of areas of our Website may not function properly, or at all, if your web browser does not accept cookies. However, you can allow cookies from specific websites by making them “trusted websites” in your web browser. The “Help” function within your web browser should tell you how to make these changes.


We may process your personal data for more than one legal basis depending on the specific purpose for which we are using your personal data. Please contact us at if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set forth below:

  • Purpose: To notify you about changes to our Website terms or this policy; and ask you to leave feedback. Data Used: Contact Data, Identity Data and Profile Data. Legal Basis: Necessary to comply with a legal or regulatory obligation; necessary for our legitimate interests of ensuring (a) you have the most up-to-date terms regarding the use of our Website, and (b) the Website is functioning as intended and if it can be improved.
  • Purpose: To manage and protect our business and this Website, including improving data security, troubleshooting data and systems, system maintenance and testing, data hosting and reporting. Data Used: Contact Data, Identity Data, Profile Data, Technical Data and Usage Data. Legal Basis: Necessary to comply with a legal or regulatory obligation;
    necessary for our legitimate interests of ensuring the efficient and secure running of the Website, including through maintaining information technology services, network and data security.
  • Purpose: To make suggestions and recommendations to you about services or content that may be of interest to you. Data Used: Contact Data, Identity Data, Marketing and Communications Data, Profile Data, Technical Data and Usage Data. Legal Basis: Necessary for our legitimate interests of developing our services and growing our business.
  • Purpose: To display targeted advertising from third-party partners. Data Used: Technical Data and Usage Data. Legal Basis: Necessary for our legitimate interests of providing information to the general public at low-or-no-cost, and growing our business.
  • Purpose: To use data analytics to improve our website, our services, marketing, customer relationships and experiences. Data Used: Technical Data and Usage Data. Legal Basis: Necessary for our legitimate interests of reviewing how users use the Website and what they think of it, thereby allowing us to improve our Website and identify ways to grow our business.

We will only use your personal data for the purposes for which we collected it as detailed in this policy, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


We may share your personal data with affiliated entities, including any of our subsidiary and parent companies and their series, branches and other subdivisions, worldwide. However, we will not share your personal data with non-affiliated third-parties without your consent, unless we are legally required to do so.

We may share personal data with payment services providers to process payments, monitor fraud and other prohibited activities, facilitate dispute resolution such as chargebacks or refunds, and for other purposes associated with the acceptance of credit or debit cards. By making a payment online, you consent to the sharing of such information.

Please be aware that we may share anonymous data, and information from third-party sources, with third-parties.


We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. This includes for example the purposes of satisfying any legal, regulatory, accounting, reporting requirements, to carry out work, for the establishment or defense of legal claims.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you would like to know more about the retention periods we apply to your personal data, please contact us at

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.


Under certain circumstances, you have rights under data protection laws in relation to your personal data. It is our policy to respect your rights and we will act promptly and in accordance with any applicable law, rule or regulation relating to the processing of your personal data.

Details of your rights are set out below:

  • Right to be informed about how personal data is used: you have a right to be informed about how we will use and share your personal data. This explanation will be provided to you in a concise, transparent, intelligible and easily accessible format and will be written in clear and plain language.
  • Right to access personal data: you have a right to obtain confirmation of whether we are processing your personal data, access to your personal data and information regarding how your personal data is being used by us.
  • Right to have inaccurate personal data rectified: you have a right to have any inaccurate or incomplete personal data rectified. If we have disclosed the relevant personal data to any third parties, we will take reasonable steps to inform those third parties of the rectification where possible.
  • Right to have personal data erased in certain circumstances: you have a right to request that certain personal data held by us is erased. This is also known as the right to be forgotten. This is not a blanket right to require all personal data to be deleted. We will consider each request carefully in accordance with the requirements of any laws relating to the processing of your personal data.
  • Right to restrict processing of personal data in certain circumstances: you have a right to block the processing of your personal data in certain circumstances. This right arises if you are disputing the accuracy of personal data, if you have raised an objection to processing, if processing of personal data is unlawful and you oppose erasure and request restriction instead or if the personal data is no longer required by us but you require the personal data to be retained to establish, exercise or defend a legal claim.
  • Right to data portability: in certain circumstances you can request to receive a copy of your personal data in a commonly used electronic format. This right only applies to personal data that you have provided to us, for example by completing a form or providing information through our Website. Information about you which has been gathered by monitoring your behavior will also be subject to the right to data portability. The right to data portability only applies if the processing is based on your consent or if the personal data must be processed for the performance of a contract and the processing is carried out by automated means (i.e. electronically).
  • Right to object to processing of personal data in certain circumstances: you have a right to object to processing being carried out by us in certain circumstances. In such circumstances, you will be informed that you have a right to object at the point of data collection and the right to object will be explicitly brought to your attention and be presented clearly and separately from any other information.
  • Right not to be subject to automated decisions where the decision produces a legal effect or a similarly significant effect: you have a right not to be subject to a decision which is based on automated processing where the decision will produce a legal effect or a similarly significant effect on you.

You may exercise any of your rights using the following contact information:
Attn: General Counsel, Kotokami LLC
110 Wall Street
New York, NY 10005
United States of America
Tel:: +1 929 376 8888

You will not have to pay a fee to access your personal data, or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one calendar month. Occasionally it may take us longer than one calendar month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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