TOHO Privacy Policy

Last Updated: 15/12/2025

Your privacy is important to us at TOHO Global Co., Ltd. and TOHO Co., Ltd. (collectively “TOHO,” “we,” “us,” or “our”), and we are committed to safeguarding, preserving, and respecting your privacy rights. This online privacy statement (the “Statement” or “Policy”) describes how we collect, use, disclose, and secure the personal information we gather about you through our websites, social media accounts, social media campaigns, and other marketing activities when you view or interact with our social media accounts or any social media accounts or content affiliated with us, when you apply to our campaigns, and when you interact with us as an applicant or potential applicant to our campaigns or otherwise.

For purposes of this Statement, personal information means data that classifies as personal information, personal data, personally identifiable information, or similar terms under applicable data privacy and security laws and regulations. It does not include data excluded or exempted from those laws and regulations. Nothing in this Statement will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to TOHO generally or in any specific context.

This Policy expressly incorporates any privacy notices we may issue to supplement this Policy, for example if required by law. Depending on your residency, a supplemental privacy notice may apply to you. For example, if you are a California resident, click here to view our California Privacy Policy.

1. You Consent to This Statement

You should read this Statement carefully, so that you understand our privacy practices. By accessing, browsing our social media account or applying to our social media campaigns, you confirm that you have read, understood, and agreed with this Statement. If you do not agree to this Statement, you may not apply to our social media campaigns.

This Statement applies regardless of how our social media account is accessed and will cover any technologies or devices by which we make our social media account available to you.

We may provide you with additional privacy notices where we believe it is appropriate to do so. It is important that you read this Statement together with any other privacy notice or terms we may provide on specific occasions, so that you are fully aware of how and why we are using your data. This Statement supplements these other notices and is not intended to override them.

Your application to our campaigns, and any dispute over privacy, is subject to this Policy and our terms of use. Terms of Use incorporated by reference into this Policy.

If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described in the “Contact Us” section below.

2. What Types of Information Do We Collect?

We collect information you voluntarily provide directly to us, information that we collect automatically when you interact with us, and information collected from third parties. The categories of personal information that we collect and the purposes for which we collect that information are described below.

Categories of Personal Information We Collect and Purposes of Collection

The following list describes the categories of personal information we collect.

• Information for our Account Management includes email address, your social media account username, profile images, followers, content of posts, comments, replies, likes, mentions, tags, etc. (“Posts”), and the content of interactions with you through Posts. We collect this information when you provide it directly to us. We collect this information for the purposes of our account operation.
• Analytics Information. We collect certain analytics information automatically as you navigate our website, social media account and other marketing activities. This includes cookies, tracking pixels, tags or similar tools, which may collect information about your browser, device, location, and interactions with us, or emails. For more information, please view the “How Do We Use “Cookies” and Other Tracking Technologies?” section below. We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance. This information may be made available to third parties as described in this Policy.
• Chat Bot Informationincludes relevant Analytics Information as well as any information that you may submit to us through the use of our chat bot or related customer service tools. Please note that when engaging with our automated tools, you may not be communicating with a live person. Please also note that we may record your communications submitted through the chat bot and disclose such recordings to our service providers, who allow us to provide these tools and functionality. We collect this information to provide customer service, improve our services, and facilitate our communications with you.
• Contact Information includes name, email address, shipping address, and phone number. We collect this information when you provide it directly to us such as application to our campaigns and delivery of prizes to winners in the campaigns. We collect this information for the purposes of conducting campaigns related to our products or services and delivering prizes to winners.
• Commercial History includes information regarding the purchases you have made from our group companies. We collect this information for the purposes of advertising and marketing, analytics and research, customer service, and website security and maintenance.
• Responses to Questionnaires includes any information you provide to us when you provide us with inquiries and correspondence thereafter.
• Marketing activities related to our products and servicesincludes any information that you provide to us when you voluntarily enter into one of our promotional offerings. This may include your social media account names, full names, gender, date of birth, addresses, profile images, followers, and content of your Posts, as well as the content of interactions with you through Posts, access history to our website, and the content of communication with prize winners. We collect this information for the purposes of advertising and marketing, analytics and research.
• Social Media Information includes information that you post by sharing on a blog or another social media platform. We collect this information when you provide it directly to us or post it publicly. Please note that your comments will be visible to the public, so you should never share personal information that you would like to keep private. We collect this information for the purposes of advertising and marketing, analytics and research, customer service, and website security and maintenance.
• User-Generated Content. If you post, upload, comment, or otherwise submit content on the Services, we may collect said content and certain information about you such as your viewing history. Be aware that as a default, any information you post on the Services, including without limitation review, comments, and text, may be available to and searchable by all users of the Services. We collect this information for the purposes of advertising and marketing, analytics and research, customer service, and website security and maintenance.

How We Disclose the Personal Information We Collect

We may disclose your personal information with certain parties that allow us to provide our social media account, social media campaigns, or other marketing activities. This may include:

• With third parties who perform data services on our behalf (e.g., hosting, maintenance, backup, analysis, etc.). Any such third parties will be under an obligation to us to maintain the confidentiality of your personal information;
• To third-party service providers to prepare, deploy, and analyze advertising content;
• To third-party service providers who provide shipping and related services that allow us to provide our social media account, social media campaigns, or other marketing activities;
• To our affiliates and parent organizations in connection with providing our social media account, social media campaigns, or other marketing activities or otherwise in connection with business operations; and
• To any other person or entity where you consent to the disclosure.

Other Ways We May Collect, Use, or Share the Information

We may also reserve the right to collect, use, or share personal information for the following purposes:

• For legal purposes.We reserve the right to cooperate with local, provincial, state, federal and international officials in any investigation requiring either personal information or reports about lawful of unlawful user activity on the website. We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention. We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
• If we are ordered by a legal process or government to provide data about one or more individual users, we will notify those users of our compliance with that order, to the extent permitted by law.
• Business transactions or mergers. We reserve the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction. Additionally, if we are entering into a corporate transaction with a third party, we may receive personal information in connection with the diligence. If we close a transaction, the third party may transfer personal information, which we would use as described in this Policy.
• Bankruptcy or insolvency. In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.
• Information from our partners. We may collect information from our partners such as market research firms and our affiliates, subsidiaries, joint ventures, or other companies under common control. We may combine that information with other information we collect about you, but we will always use the information as described in this Policy. We collect this information for the purposes of marketing, advertising, research, and analytics.

Joint Use of Personal Information

Within the scope of the purposes of use listed in Section 2 above, we may jointly use personal information concerning you listed in Section 2 above, such as social media account names, names, and addresses, with our group companies (listed at: https://www.toho.co.jp/company/group) in accordance with the Act on the Protection of Personal Information of Japan, with TOHO as the party responsible for managing such joint use.

3. How Do We Use “Cookies” and Other Tracking Technologies?

We and our third-party providers may send one or more cookies to your computer or other device. We and our third-party providers may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our websites. These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with us. This information allows us to understand how you access our websites, improve the functionality of our websites, and conduct targeted advertising and marketing efforts. We implement both first and third-party cookies and related technologies. As such, the information collected through these cookies may also be available to third parties, including advertising networks and analytics providers. These parties may use the information collected through their cookies for their own purposes, including analytics, advertising, and creating user profiles.

What Are Cookies?

Cookies are small files created by websites, including our services, that reside on your computer’s hard drive and that store information about your use of a particular website. When you access our services, we use cookies and other tracking technologies to:

• Estimate our audience size and usage patterns;
• Store information about your preferences, allowing us to customize our services according to your individual needs;
• Contact you to provide you with information or services that you request from us;
• Advertise new content, events, and services that relate to your interests;
• Provide you with more personalized content that is most relevant to your interest areas; and
• Recognize when you return to our services.

We set some cookies ourselves and others are set by third parties. You can manage your cookies preference as described in the “Managing Your Cookies” section below.

What Types of Cookies Do We Use and Why?

The following chart lists the different types of cookies that we and our service providers use on the services, examples of who serves those cookies and links to the privacy notices and opt-out information of those cookie servers. Because the specific cookies we use may vary over time, as well as differ by the specific page you are browsing, the below chart is illustrative only.

We do not use analytical tools in a manner that discloses to third parties that a specific person viewed specific video materials. However, we may use embedded video content that provides you access to content hosted on third party websites. The hosts of such embedded videos may place cookies on your device when you view their content. Any cookies or other information collected through such embedded videos are subject to the terms of the provider’s privacy policy.

How Long Do Cookies Stay on My Device?

Some cookies operate from the time you visit the services until the end of that particular browsing session. These cookies, which are called “session cookies,” expire and are automatically deleted when you close your Internet browser.

Some cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser. These cookies are called “persistent cookies” and the length of time they will remain on your device will vary from cookie to cookie. Persistent cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the services, how your use of the services may change over time, and the effectiveness of advertising efforts.

Managing Your Cookies

We provide you with the ability to control our use of cookies through our Cookie Banner. You may click here to change your cookie preferences.

It may also be possible to block cookies by changing your Internet browser settings to refuse all or some cookies. If you choose to block all cookies (including essential cookies), you may not be able to access all or parts of the services.

You can find out more about cookies and how to manage them by visiting www.AboutCookies.org.

Does the website Respond to “Do Not Track” Signals?

At this time, we do not recognize or respond to browser-initiated Do Not Track signals for residents unless otherwise specified, such as through the use of the Global Privacy Control for residents of California.

4. Additional Disclosures for TEXAS RESIDENTS ONLY

In addition to the rights described above, we provide Texas residents with specific rights regarding our processing of Personal Information. To learn more, please click here. These rights include:

1. The right to confirm whether we process personal information about you;
2. The right to correct inaccuracies in personal information we may process about you;
3. The right to delete personal information held about you;
4. The right to obtain Personal Data held in a digital format provided by you;
5. The right to opt-out of the processing of Personal Data for purposes of:
   • Targeted Advertising;
   • The Sale of personal Data; or
   • Profiling in furtherance of decisions that produce a legal or similarly significant effect.

Although TA does not sell or share your personal information for money, its use of online analytics and advertising cookies may constitute the sale of information or use of information for targeted advertising purposes under certain laws. Therefore, we allow you to opt-out of our use of cookies and related technologies. To learn more, please click here.

Residents of Texas, and their authorized representatives, may submit any other requests in accordance with the “Contact Us” section, below.

Should you disagree with any response to a request, you may appeal the decision by complying with the instructions contained in the response to the request or contact us using the information below in the "Contact Us" section. Use the subject “Data Privacy Request Appeal” and describing the nature of your appeal.

5. Canadian Users’ Rights

Residents of Canada are entitled to certain rights under the federal Personal Information Protection and Electronic Documents Act or the provincial data protection laws of Quebec, Alberta, or British Columbia, depending on their residency. These rights include the right to access, the right to challenge the accuracy and completeness, and the right to correct the personal information we process about you. If you are a Canadian resident and would like exercise your rights under the applicable data protection laws in Canada, you may contact us at any time by using the information in the "Contact Us" section below.

6. How Long Is Your Personal Information Kept

We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided.

Specifically, the storage periods are as follows:

(1) For information necessary for delivery of prizes to winners in the campaigns: One (1) year from the date of collection.

(2) For information related to inquiries from you as social media users or applicants to our campaigns: One (1) year from the date of receipt.

We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements.

We will delete your personal information when it is no longer necessary for the purpose for which it was collected, or upon your request, subject to exceptions as discussed in this Statement or under applicable law, contract, or regulation.

7. Our Commitment to Data Security

The security of your personal information is important to us. We take various reasonable organizational, administrative, and technical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. If required by law to do so, we will notify you and/or the relevant supervisory authority in the event of a data breach.

However, we cannot and do not guarantee complete security, as it does not exist on the Internet.

Further details regarding the security control measures we implement for personal information processing can be obtained and confirmed by contacting us using the contact information described in the “Contact Us” section below.

8. Where Your Personal Information Is Held

We process personal information on third-party servers in the United States of America, and may do so in other countries. If you access our websites, social media accounts, apply to our social media campaigns or otherwise provide us with information from outside of the United States, you expressly consent to the transfer of your data to the United States, the processing of your data in the United States, and the storage of your data in the United States.

9. Third Party Links

TOHO’s websites, social media accounts, social media campaigns, and other activities may contain links to third-party websites. When we provide links, we do so only as a convenience and we are not responsible for any content of any third-party website or any links contained within. It is important to note that this Statement only applies to TOHO’s websites, social media accounts, social media campaigns, and other activities. We are not responsible and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting third-party websites. We also advise that you carefully read the privacy notice of any third-party websites you choose to visit.

10. Children’s Privacy

Protecting the privacy of the very young is especially important. Our websites, social media accounts, social media campaigns, and other activities are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. In the event that we learn that we have collected personal information from a child under age 13 without verification or parental consent, we will immediately delete that information. If you believe that we might have any information from or about a child under 13, please contact us using the information provided in the “Contact Us” section below.

11. Policy Changes

This Statement may change from time to time. If we need to change this Statement at some point in the future, we will post any changes on this page. If we make a significant or material change to this Statement we will notify you via email. You should check these terms when you access our websites, social media accounts or apply to our social media campaigns. Your continued access to our websites, social media accounts or application to our social media campaigns constitutes acceptance of the most current version of this Statement

12. Contact Us

If you have any questions about this Privacy Policy, please contact us by email at
legal@tohointl.com.