Privacy policy

This Website is provided and managed by Koto Studio Ltd (referred to as “we”, “us” or “our” in this Privacy Policy) on behalf of the Koto Group.

Koto Studio Ltd will be the data controller of any personal data that we use to send direct marketing to you and that we collect about you on the Website.

The Koto Group consists of the following companies as shown in the list below (Territory, Company details):

• UK, Koto Studio Ltd, Company Number 09297454

• Germany, Koto Studio GmbH, Company Number 87457750

• Australia, Koto Studio Pty Ltd, ABN 27667228579

• New York, Koto Studio NYC Inc., 240624001070

• Los Angeles, Koto Studio LA Inc., 222086524

We will only use your personal data where we have a lawful basis to do so. In particular, we will usually only use your data:

• where you have consented to us doing so; or

• in ways which might reasonably be expected as part of running our business, and which does not materially impact your interests, rights or freedoms. For example, to administer our Website and send business-to-business direct marketing. Please contact us using the details below if you would like further information about this.

We may sometimes need to use data to comply with our legal obligations (for example to pass on details of people who are involved in fraud).

Further details of how we will use your personal information are provided below.

Cookies and Tracking Pixels:

We may collect personal data about you through cookies on our Website and tracking pixels on our direct marketing emails. Personal data collected may include:

• browsing behaviour such as emails opened and responded to, pages visited, time spent on pages and emails, referral source and navigation paths;
• geolocation data such as IP address, country and city; and
• device and browser information such as device type, operating system, browser and connection latency.

We will use this personal data:

• to administer and improve our Website and direct marketing activities and to ensure they are presented in the most effective manner for you;
• to give you the best Website experience and to allow you to participate in interactive features of our Website if you choose to do so;
• for data analysis, testing, research and statistical statistics to help us to improve our Website and direct marketing activities. For example, to understand responses to outbound marketing content from us, such as email and social media posts;
• to keep our Website safe and secure; and
• to understand browsing behaviour and website analytics such as emails opened and responded to, pages visited and time spent on pages, to identify behavioural flows, and to profile website visitors and email recipients.

Full details as to how we process and use cookies can be found on our Cookies Policy which can be accessed by clicking the “Privacy” button on the bottom left of every page of our Website.

Direct Marketing Activities:

We may collect your contact details for use for direct marketing purposes:

• directly from you, for example, when you subscribe to our OFF Brand Newsletter on our Website, order goods/services from us or otherwise interact with us; or
• from our service provider Apollo, described below. Apollo acts as an independent controller when sharing such contact details with us. These contact details will include names, job titles, employers, email addresses and LinkedIn URLs. Please visit Apollo’s Privacy Policy to understand how such contact details are included in Apollo’s contributor database and shared with us and other third parties. If you have any queries or would like to exercise your rights in relation to Apollo’s contributor database, please contact Apollo using the details provided in its Privacy Policy. For clarity, whilst we are provided with contact details from Apollo’s contributor database, we do not contribute any details (including any of your personal data) to such database.

We will use such contact details to send you direct marketing by email and/or on LinkedIn.

Where you have subscribed to our OFF Brand Newsletter, we rely on consent to send such emails. As explained below, you can withdraw your consent at any time.

Otherwise, we rely on the lawful basis of legitimate interests to send business-to-business direct marketing. Please contact us using the details below if you would like further information about this.

We may share your personal data within the Koto Group and with our service providers including Apollo and HubSpot, who provide CRM, direct marketing and email tracking services.

We may also share your personal data with trusted third parties who set cookies on our Website. These third parties are listed in our Cookies Policy which can be accessed by clicking the “Privacy” button on the bottom left of every page of our Website.

These service providers and third parties may also collect personal data directly from you.

We may be required to share your personal data with the police, administrative authorities (such as HMRC) or other enforcement, regulatory or Government bodies, where we are legally obliged to do so.

Some of the Koto Group and these service providers and trusted third parties are located in countries outside of the UK and EU, such as the United States.

As a result, the personal data that we or the trusted third parties collect from you may be transferred to or accessed from outside the UK and EU.

If we do this, we have procedures in place to ensure your data receives the necessary protections. Any transfer of your personal data will follow applicable laws, and we will treat the information according to the principles set out in this Privacy Policy.

If you would like further information, please contact us using the details provided at the end of this Privacy Policy.

We will only keep your personal data for as long as we need to for the reason we collected it, as set out in this Privacy Policy. Our Cookies Policy (which can be found by clicking the “Privacy” button on the bottom left of every page of our Website) confirms the timespan of each cookie.

We may also keep hold of some of your personal data if we are required to do so for legal purposes, for example, to meet our legal or regulatory requirements or to prevent fraud and abuse.

You have the following rights in relation to the personal information we hold about you, to request:

• access to the personal data we hold about you (commonly known as a “data subject access request”) including a copy of it;

• the correction of the personal information that we hold about you if it is incomplete or inaccurate;

• the deletion or removal of personal data we hold about you where there is no good reason for us continuing to process it or where you have exercised your right to object to processing (see below);

• for our processing of your personal information to be restricted in certain circumstances, for example if you want to establish its accuracy or the reason for processing it;

• to obtain a copy of the personal information you have provided us with and to reuse it elsewhere or to ask us to transfer it to a third party of your choice; and

• to withdraw any consent you have provided to our use of your personal data. Where you withdraw consent, we will stop using your data for the specific purpose, unless we have an alternative legal basis to use it.

Where we are processing your personal data on the basis of our legitimate interests, you can ask us to stop processing it and we must do so unless we believe we have an overriding legitimate reason to continue processing your personal data.

If you are dissatisfied with how we have handled your personal data, you have the right to make a complaint to your data protection regulator. In the UK, this is the Information Commissioner’s Office (ICO). You can make a complaint to the ICO by calling their helpline on 0303 123 1113 or on their website at www.ico.org.uk/concerns. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or, (if you’re based outside of the UK, your data protection regulator), so please do contact us in the first instance.

If you have any queries regarding this Privacy Policy, you have a complaint or you would like to exercise any of your rights set out above, you can contact our Data Protection Officer in the following ways:

• by email at privacy@koto.studio; or

• by post at FAO: Data Protection Officer, Koto Studio Ltd, 1st Floor, 127-131, Great Suffolk St, London SE1 1PP.

This Privacy Policy was last updated on 29th May 2025.