Privacy Notice

1. Introduction

This Privacy Notice explains how Toku Ltd. ("Toku", "we", "us", or "our") collects, uses, and discloses personal data through the Makimoto website at makimoto.ai (the "Website") and the Makimoto early-access waiting list (the "Waiting List").

Makimoto is an open-source initiative operated by Toku through its subsidiary, Makimoto Technology Pte. Ltd. For the purposes of personal data processed via the Website and the Waiting List, Toku Ltd. is the data controller and is committed to complying with the Singapore Personal Data Protection Act 2012 (the "PDPA").

This Privacy Notice applies in addition to any other privacy notices or consents that may apply to your interactions with Toku, but only in relation to the personal data processed through the Website and the Waiting List. If you do not agree with this Privacy Notice, please do not use the Website or sign up for the Waiting List.

We may update this Privacy Notice from time to time. The "Last updated" date at the top of this page indicates when the Notice was last revised. Continued use of the Website after a revised Notice has been posted constitutes your acceptance of the revised Notice.

2. Personal data we collect

In this Privacy Notice, "personal data" refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

We collect the following personal data when you interact with the Website:

2.1 Information you provide via the Waiting List sign-up form

• First name and last name
• Work email address
• Company name
• GitHub username (if provided)
• Information about your intended use case for Kawa, including the type of API you expect to use, the jurisdictions in which you require data to be processed, and your expected usage volume (if provided in the second step of the form)
• Any additional information you choose to provide in free-text fields

2.2 Information collected automatically when you visit the Website

• Browser type and version, operating system, and device information
• IP address (which may indicate approximate geographic location)
• Pages visited, time spent on the Website, and referring website
• Cookies and similar technologies (see Section 7 below)

2.3 Information you provide through other channels

If you contact us by email, through Discord, or through any other channel referenced on the Website, we will collect the personal data you choose to share in those communications.

3. Why we collect your personal data

We use your personal data for the following purposes:

• To manage your Waiting List registration. We use your name, email address, company name, and use-case information to confirm your registration, prioritise early access to the Kawa API, and contact you when access is granted.
• To communicate with you about Makimoto. We may send you updates about the Makimoto initiative, the Kawa product roadmap, and the launch of the API. You can opt out of these communications at any time using the contact details below.
• To improve the Website and the Makimoto initiative. We use aggregated, deidentified information about Website visits to understand which content is useful to developers and to improve the experience.
• To comply with legal obligations. We may use your personal data to comply with applicable laws, regulations, or legal processes, including responding to requests from public authorities.
• To protect the security of the Website. We may use technical information to detect, prevent, and respond to security incidents, fraud, or other harmful activity.

4. Who we share your personal data with

We do not sell your personal data. We may share your personal data with the following categories of recipients:

• Toku affiliates. Including Makimoto Technology Pte. Ltd., the subsidiary that operates the Makimoto initiative on behalf of Toku Ltd.
• Service providers. Trusted third parties that help us operate the Website and the Waiting List, including hosting providers (currently Amazon Web Services), email and communications platforms, and analytics providers. These service providers are bound by contractual obligations to handle your data securely and only for the purposes we specify.
• Professional advisors. Our legal, accounting, and other professional advisors, where necessary in the ordinary course of our business.
• Authorities. Government regulators, statutory boards, or law enforcement, where required by applicable law or to protect our legal rights.
• In the context of a corporate transaction. In the event of a merger, acquisition, financing, or similar transaction involving Toku Ltd or Makimoto Technology Pte. Ltd.

5. Where your personal data is processed

Personal data collected through the Website is hosted in Singapore. Where we transfer personal data outside Singapore, we take steps to ensure the data continues to be protected at a comparable standard, in accordance with the PDPA and the cross-border transfer requirements of any applicable jurisdiction.

6. How long we keep your personal data

We keep your personal data only as long as necessary for the purposes described in this Privacy Notice or as required by applicable law. For Waiting List registrations, we keep your information until you ask us to delete it, you opt out of our communications, or twenty-four months pass with no further interaction, whichever comes first. After this period, we will delete or anonymise your personal data.

7. Cookies and similar technologies

A cookie is a small piece of information placed on your device when you visit the Website. We use cookies for the following purposes:

• Strictly necessary cookies, which enable core Website functions such as remembering form input during the Waiting List sign-up.
• Analytics cookies, which help us understand how visitors use the Website, so we can improve the experience.

Most internet browsers allow you to control cookies through your browser settings. Disabling cookies may limit some Website functionality.

8. Your rights

Subject to applicable law, you have the following rights in relation to your personal data:

• Access. You may request a copy of the personal data we hold about you.
• Correction. You may ask us to correct or update inaccurate or incomplete personal data.
• Withdrawal of consent. You may withdraw your consent to our processing of your personal data, including by unsubscribing from our communications or asking to be removed from the Waiting List. Withdrawing consent may prevent us from continuing to provide you with information about Makimoto or early access to the Kawa API.
• Deletion. You may ask us to delete your personal data, subject to any applicable legal retention obligations.

To exercise any of these rights, please contact us using the details in Section 10 below. We will respond to your request within thirty days, or such shorter period as required by applicable law.

9. Security

We take reasonable steps to protect your personal data against loss, misuse, unauthorised access, alteration, and disclosure. These steps include technical safeguards such as encryption in transit, organisational safeguards such as access controls, and contractual safeguards with our service providers. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

In the event of a personal data breach affecting your information, we will notify you and the relevant authorities in accordance with the requirements of the PDPA and any other applicable law.

10. How to contact us

If you have questions about this Privacy Notice, wish to exercise any of your rights, or want to make a complaint about how we handle your personal data, please contact us at:

• Email: dpo@toku.co
• Postal address: Toku Ltd., 61 Robinson Road, #08-02, Singapore 068893

You also have the right to lodge a complaint with the Singapore Personal Data Protection Commission ("PDPC") if you believe your rights under the PDPA have been breached. More information is available at www.pdpc.gov.sg.