Privacy Policy

1. INTRODUCTION

This Privacy Policy governs the practices of how Takara Tech (referred to herein as "we", "our", "ours" or "us") collects, uses, transfers, and shares personal information related to the use of our Services by our Users (referred to herein as “you”, “your”, or “yours”). This Policy is designed to ensure the transparent, lawful, equitable, and secure management of the personal data of our Users.

This Privacy Policy explains how we collect, use, disclose, and protect personal information in connection with our demand‑side platform and related services (collectively, the “Platform”). Moreover, it explains how you as a data subject may exercise your rights in relation to your personal data.

We may update this Privacy Policy from time to time. When we do, we will post the updated version on this page and revise the “Last Updated” date. If we make material changes, we may also provide additional notice—such as a website notice or an email—at our sole discretion.

We strongly encourage you to read this Policy in its entirety to understand the processes involving your data and your associated rights. For inquiries related to this Privacy Policy, data collection and usage, data disclosure, and sharing, or any other concerns or requests related to your personal data, please do not hesitate to get in touch with us by writing to us at info@takaratech.jp or use the methods listed in the Get in Touch section.

2. DEFINITIONS

In this Policy, words with an initial capitalized letter are assigned specific meanings under the conditions described herein. These definitions shall retain their consistent meaning irrespective of their grammatical form (singular or plural).

The following section covers the basic definitions used in this Privacy Policy. It describes what is meant by your personal data and who controls and processes your personal data.

• Policy refers to this Privacy Policy, including any updates or amendments that may be made.
• Service refers to all the related functions and content that we offer.
• Cookies refer to small files placed on your computer, mobile device or any other device by a website, containing details of your browsing history on that website among its many uses.
• Ad (including advertisement) refers to paid message created by or for a sponsor to promote a product, service, brand, idea, or action to a target audience through media channels (e.g., websites, apps, TV, CTV, audio, social, print, out‑of‑home). The rule regarding initial capitalized letters does not apply to this term.
• Applicable Law refers to any law, rule, regulation, statute, ordinance, protocol, guideline, treaty, or judicial, administrative, or departmental directive, ruling, or order (whether in Hong Kong or another jurisdiction) intended to govern or regulate any party, property, transaction, or activity related to these Terms. This includes rules issued by any governmental or regulatory authority.
• Personal Data refers to any information that relates to an identified or identifiable natural person. This includes details like names, addresses, email addresses, identification numbers, and even things like IP addresses or cookie identifiers, as well as any information found online that may reveal your physical, genetic, mental, economic, cultural or social identity.
• Data Subject refers to the person who the personal data is about. In simpler terms, it’s you or any other individual whose personal information is being collected and processed.
• GDPR-covered user refers to the individuals whose personal data is subject to the protections and regulations set forth by the General Data Protection Regulation. GDPR is the regulation in European Union (“EU”) law that focuses on data protection and privacy for individuals within the EU and the European Economic Area. In compliance with the European Securities and Markets Authority guidelines under the Markets in Crypto-Assets Regulation as at July 2025, we do not accept clients from these jurisdictions unless they have independently sought our services without any prior engagement, marketing, or solicitation from us.

3. OUR PLATFORM

Takara Tech is a programmatic advertising platform. We provide tools and services to advertisers and advertising agencies to plan, buy, deliver, measure, and optimize digital advertising campaigns across formats such as native, display, video, connected TV (CTV), and audio.

Through the Platform, we:

• Distribute and promote advertising content (“Creatives”) using real‑time, data‑driven audience targeting on behalf of our clients.
• Help clients curate audiences likely to respond to interest‑based advertising.
• When requested, assist with creative development.
• Participate in real‑time bidding (RTB) auctions to purchase ad inventory across publisher properties. When a bid is won, we deliver the client’s ad to the relevant property.
• Provide measurement and reporting so clients can understand delivery and performance (e.g., impressions, clicks, conversions).

4. INFORMATION WE COLLECT

4.1 Information You Provide To Us

We may collect information that directly identifies you when you interact with us outside of the ad delivery context, such as when you:

• Request a demo, contact support, or otherwise communicate with us.
• Create a client account or user profile in the Platform.
• Subscribe to marketing communications or attend events.

This may include your name, business email address, phone number, company, job title, and correspondence. This information is not used for ad targeting within the Platform unless a client or partner independently provides it to us for that purpose in accordance with their own privacy disclosures and Applicable Law.

4.2 Information Collected Through the Platform

When we deliver or measure ads via the Platform, we typically collect data that does not directly identify you but may be associated with your device or browser (“pseudonymous identifiers”), such as:

• Cookie IDs and similar online identifiers
• Mobile advertising IDs (e.g., IDFA, AAID)
• IP address and inferred location (e.g., city/region, not precise GPS)
• Device type, operating system, browser type and version
• Language, time zone, network type, screen resolution
• Ad event data (e.g., page/ad URL, timestamp, ad placement, bid request data, auction results, impression and click events, scroll/viewability signals, video playback metrics)
• Conversion events, where enabled by a client (e.g., page visits, form submissions, purchases) using tags, pixels, SDKs, or server‑to‑server integrations
• Contextual information about the page or app where the ad appears (e.g., content category)

4.3

We do not knowingly collect information that directly identifies you (such as your name or email) via the ad delivery process unless a client has lawfully provided or directed us to use such information in hashed or otherwise permitted form and with appropriate notice and choice.

4.4 Sources of Information

• Our clients and partners (advertisers, agencies, data providers, publishers, SSPs/ad exchanges) who send us bid requests, audiences, or measurement data.
• Your device or browser via cookies, pixels, SDKs, tags, and server‑to‑server integrations implemented by us or our partners.
• Publicly available sources and third‑party data providers, where permitted by law.

5. HOW WE USE INFORMATION

5.1 We use the information we collect to:

• Enable RTB and deliver ads, including frequency capping, sequencing, and fraud prevention.
• Select and optimize ads and audiences, including interest‑based advertising and contextual targeting.
• Measure performance, attribution, and reach; provide analytics and reporting to clients.
• Maintain, secure, and improve the Platform; debug, test, and develop new features.
• Comply with legal obligations, enforce terms, and prevent, detect, and investigate fraud, abuse, or security incidents.
• Communicate with clients and prospects, including service announcements and marketing (you can opt out of marketing at any time).

5.2 Legal Bases for Processing (EEA/UK/Relevant Jurisdictions)

Where required, we rely on one or more of the following legal bases:

• Consent (e.g., where a publisher or client obtains your consent for cookies/MAIDs/interest‑based ads).
• Legitimate interests (e.g., to provide and secure the Platform, measure performance), balanced against your rights and expectations.
• Performance of a contract (e.g., to provide services to clients).
• Compliance with legal obligations.

6. HOW WE SHARE INFORMATION

6.1 We may share information with:

• Clients and their service providers, to deliver, measure, and optimize their campaigns.
• SSPs, ad exchanges, publishers, and measurement vendors involved in the ad transaction.
• Data providers and verification partners (e.g., viewability, brand safety, anti‑fraud).
• Service providers that process data for us under contract (e.g., hosting, security, analytics, billing).
• Corporate transactions (e.g., merger, acquisition, asset sale), subject to appropriate safeguards.
• Authorities or other parties when required by law or to protect rights, safety, or the integrity of the Platform.

6.2

We do not sell personal information in the colloquial sense. Depending on your jurisdiction’s definitions (e.g., “sale” or “sharing” under the CCPA/CPRA), our disclosure of identifiers and ad event data to partners for interest‑based advertising may be considered a “sale” or “sharing.” See Your Rights and Choices for how to opt out.

7. COOKIES AND SIMILAR TECHNOLOGIES

7.1 What is a Cookie?

We use cookies on our website to gather information about our users’ interaction with our Services. Information we collect via cookies may include your use of the Website and Platform features, the frequency of your visits, your interaction with the functionalities of the Services, and other relevant information. We use Cookies to ensure the secure operation of our Services, enhance your experience, and support the delivery of all web-based features. Cookies help us understand how our Services are used, remember your preferences, and tailor our platform to better suit your needs.

Cookies are small pieces of text sent by your web browser when you visit our Website. Cookies may store user preferences and other information. Cookies provide a convenience feature to save you time or tell the Web server that you have returned to a specific page. A cookie file is stored in your web browser and allows the Service or a third party to recognize you and make your next visit easier and the Service more useful to you. For instance, upon visiting the Platform, Google Stats will track the Platform’s performance and assess online advertising effectiveness, but only when you access the Website.

Cookies can be “persistent”, “session”, “first-party” or “third-party” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.

In addition to persistent and session cookies, cookies can be categorized into first-party and third-party. Cookies set directly by us are called “first-party cookies”. Cookies set by parties other than the website owner are called “third-party cookies”. Third-party cookies enable third-party features or functionality to be provided on or through the website.

When accessing the Website, you will be asked to confirm your choice regarding cookie preferences, such as what cookie categories you wish to accept and which cookies you want to decline, or a choice to decline all cookies altogether. If you choose to accept all or some of these cookies, please note that the following information contained in this Section relates to cookies used on our Website and the Platform only and does not apply to any other pages and websites that may be hyperlinked to our Website. To read more about the categories of cookies used on our Website, please refer to the next subsection. For more general information about cookies and their use, you may visit http://www.allaboutcookies.org/.

7.2

We and our partners use cookies, pixels, SDKs, tags, local storage, and similar technologies to:

• Recognize your browser or device.
• Enable bidding, ad delivery, frequency capping, and measurement.
• Conduct analytics and help prevent fraud.

7.3

You can manage cookies via your browser settings and device advertising settings. Opting out may still allow ads, but they may be less relevant.

8. DATA RETENTION

We retain personal information for as long as necessary to fulfill the purposes described in this policy, including providing the Platform, complying with legal obligations, resolving disputes, and enforcing agreements. The retention periods may vary depending on the type of personal information and the purposes for which it was initially gathered but will not be processed for more than 10 years after the original purpose of collection has been achieved, unless there are specific requirements stipulating otherwise for certain data. After this period, your personal data will only be retained if it has been anonymized.

9. SECURITY

We consider the security of your personal information to be of paramount importance. We employ a range of technical, organizational, and administrative measures designed to safeguard your data against unauthorized access, disclosure, alteration, and destruction, including encryption in transit, access controls, network safeguards, and regular monitoring. Please be noted that no method of transmission or storage is completely secure.

10. YOUR RIGHTS

10.1

Depending on your location, you may have rights regarding the personal data that we collect and use. These rights are designed to provide you with control and transparency over your data. The following are your rights as a data subject:

• Right to Access: You have the right to request access to the personal data we hold about you. This includes the right to obtain confirmation of whether we are processing your personal data and, if so, access to specific details of that processing.
• Right to Rectification: If you believe that the personal data we hold about you is inaccurate or incomplete, you have the right to request the correction or completion of such data.
• Right to Erasure (Right to Be Forgotten): You have the right to request the deletion of your personal data under certain circumstances. This right is not absolute and may be subject to legal requirements or legitimate interests that override your request.
• Right to Restriction of Processing: You can request the restriction of processing of your personal data in certain situations. This means that we will limit the way in which we use your data, but we may continue to store it.
• Right to Data Portability: In some cases, you have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller.
• Right to Object: You have the right to object to the processing of your personal data, including for direct marketing purposes or when we rely on legitimate interests as our legal basis for processing.
• Rights Related to Automated Decision-Making and Profiling: We commit to transparent and fair automated decision-making processes. If you are subject to automated decision-making that produces legal effects or significantly affects you, you have the right to request human intervention and reconsideration of the decision.

10.2

To exercise any of the rights outlined above or if you have any questions or concerns regarding the processing of your personal data, please contact us via our official communication channels. Our dedicated personnel will assist you in addressing your data-related inquiries and ensuring that your rights as a data subject are respected and upheld.

You will not be charged a fee for accessing your personal data or exercising any of the rights outlined above. In the rare event that your request is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee. This fee, if applicable, will be based on the administrative costs associated with processing your request. Alternatively, we may choose to refuse to comply with your request in these exceptional circumstances. If such a situation arises, we will provide a clear and transparent explanation for our decision. Please note that we will always act in accordance with applicable data protection laws and regulations when assessing the reasonableness of any fees or the validity of requests.

We are committed to responding promptly to legitimate requests regarding your personal data. Our best practice is to reply to such requests within one month from the date of receipt. However, in situations where the request is particularly complex or there is a high volume of requests, we may extend this period by up to two further months as necessary. This extension will be based on a careful consideration of the complexity and number of requests received.

10.3

In addition to the means of exercising your rights outlined above, you have the right to lodge a complaint about our practices with the competent authorities of the country where you reside:

• If you reside in the EEA, the UK, or Switzerland, you have the right to lodge a complaint with the data protection authority of your country. You can find the list of data protection authorities of the EU and EEA countries with contact details here: https://dataprivacymanager.net/list-of-eu-data-protection-supervisory-authorities-gdpr/. In the UK, the supervisory authority is the Information Commissioner’s Office, see the ICO’s official website for more detailed information at https://ico.org.uk/.
• If you reside outside of the EEA, the UK, or Switzerland, you may turn to your local supervisory authorities for lodging a complaint about our privacy practices. We encourage you to visit the website administered by the French National Commission for Information Technology and Liberty (CNIL), where you can find the data protection authority for your jurisdiction: https://www.cnil.fr/en/data-protection-around-the-world

11. CHILDREN’S PRIVACY

Our Service is not directed to, nor does it knowingly collect information from, anyone under the age of 18. We do not knowingly collect personally identifiable information from individuals under the age of 18. If you are a parent or guardian and you become aware that your child has provided us with personal data, please contact us immediately. Should we discover that we have collected personal data from anyone under the age of 18 without verifiable parental consent, We will promptly take steps to remove that information from our servers.

Furthermore, if we are required to rely on parental consent as a legal basis for processing your information, and your country’s regulations mandate consent from a parent, we may necessitate your parent’s explicit consent before we proceed with the collection and use of that information.

12. INTERNATIONAL DATA TRANSFERS

We may transfer, store, and process information in countries other than where it was collected, including the United States and other jurisdictions where we or our service providers operate. Where required, we implement appropriate safeguards, such as Standard Contractual Clauses, and take supplementary measures as needed.

13. DATA MINIMIZATION AND SENSITIVE CATEGORIES

We prohibit the ingestion or targeting of sensitive categories of personal information where required by law or industry codes (e.g., precise geolocation, health diagnoses, sexual orientation, religious beliefs) unless expressly permitted and with appropriate safeguards and consents. We instruct clients not to send us sensitive data through the Platform.

14. DO NOT TRACK

Our services do not currently respond to “Do Not Track” signals. We honor legally recognized opt‑out signals where applicable (e.g., GPC under CPRA) and will apply them to the extent required by law.

Third‑Party Links and Services Our website and Platform may contain links to third‑party sites and services. We are not responsible for their privacy practices. Review their policies before providing personal information.

15. TRANSLATION AND AMENDMENT

15.1

If we provide these Terms in a language other than English, the English version will control in the event of any conflict or dispute.

15.2 Amendments.

We may modify this Policy at any time in our sole discretion. Changes take effect when posted on our website (or as otherwise stated). You are responsible for reviewing the most current version. Your continued use of the Services after changes become effective constitutes acceptance of the revised terms. If you do not agree, you must stop using the Services immediately.