PRIVACY POLICY
Kotodama Lab Sdn Bhd
www.kotodama.tokyo
Last Updated: October 2025
1. INTRODUCTION
Kotodama Lab Sdn Bhd (“We,” “Us,” “Our,” “Company”) is committed to protecting your privacy and ensuring you have a positive experience on our website and during your participation in the “Mimpi Kita: Castle In The Air” crowdfunding campaign (“Campaign”).
This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data in compliance with the Personal Data Protection Act 2010 (PDPA) and other applicable Malaysian privacy laws.
Please read this Privacy Policy carefully. If you do not agree with our practices, please do not use our Platform or participate in the Campaign.
2. DEFINITIONS
- Personal Data: Any information relating to an identified or identifiable natural person
- Processing: Any operation performed on personal data, including collection, use, storage, transfer, or deletion
- Data Controller: Kotodama Lab Sdn Bhd (the entity responsible for determining how and why personal data is processed)
- Data Subject: You, the pledger or website visitor whose personal data is collected
- Third-Party Service Provider: External vendors who process data on our behalf (payment processors, email services, etc.)
3. PERSONAL DATA WE COLLECT
3.1 Directly Provided by You
When you pledge to the Campaign or interact with our Platform, we collect:
Essential Pledge Information:
- Full name
- Email address
- WhatsApp mobile number
- Physical address (for ticket redemption coordination)
- Payment information (processed securely through third-party payment gateways)
- Pledge tier selected (RM 2, RM 5, or RM 10)
- Pledge timestamp and transaction ID
Optional Community Contributions:
- Family photographs from the 1960s or personal memorabilia
- Family stories, memories, and written narratives
- Names and details of family members featured in contributions
- Usage rights and permissions for production design purposes
Communication:
- Any messages sent to us via email or through the Platform
- Feedback, inquiries, or support requests
3.2 Automatically Collected Information
When you visit www.kotodama.tokyo, we may automatically collect:
- IP address
- Browser type and version
- Operating system
- Pages visited and time spent on each page
- Referrer source (how you found our website)
- Device information
- Approximate geographic location (country/city level)
Cookies & Tracking Technologies: We may use cookies and similar technologies to remember your preferences, improve your experience, and analyze website usage. You can control cookie settings through your browser preferences.
3.3 Information from Third Parties
- Payment processors provide transaction confirmation and payment status
- WhatsApp Business API provides message delivery status
- Anti-Gravity Euphoria Sdn Bhd may provide additional context for verification purposes
4. PURPOSES OF DATA COLLECTION & PROCESSING
We process your personal data only for the following lawful purposes:
4.1 Campaign Administration
- Processing and recording your Pledge
- Verifying Pledge legitimacy and fraud prevention
- Assigning Pledge tier and Reward entitlements
- Generating Special Thanks credits
4.2 Reward Fulfillment
- Delivering OST download links (RM 10 tier)
- Contacting you via WhatsApp regarding film ticket availability and redemption
- Sending Special Thanks credit confirmations
- Coordinating delivery of Project updates and Rewards
4.3 Communications
- Sending Campaign updates and Project milestones
- Notifying you of Reward delivery and redemption details
- Responding to your inquiries or support requests
- Sending promotional materials about the Project (with your consent)
4.4 Legal & Compliance
- Fulfilling legal obligations under Malaysian tax and financial regulations
- Preventing fraud, abuse, or unlawful activity
- Enforcing our Terms & Conditions
- Protecting our legal rights and interests
4.5 Production Design & Marketing
- Using your submitted community contributions (photos, stories) for the film’s production design
- Featuring contributor stories on our social media platforms
- Creating behind-the-scenes marketing content
- Providing attribution and credits in the film and promotional materials
4.6 Website Analytics & Improvement
- Analyzing Platform usage patterns to improve user experience
- Measuring Campaign effectiveness
- Identifying technical issues and optimizing website performance
Important: We will not process your personal data for purposes other than those listed above without obtaining your explicit consent.
5. LEGAL BASIS FOR PROCESSING
Under the PDPA, we process your personal data based on the following legal grounds:
- Contract Performance: Processing necessary to fulfill your Pledge and deliver Rewards
- Legal Obligation: Complying with Malaysian tax, financial, and regulatory requirements
- Consent: You have provided explicit consent for specific uses (e.g., marketing communications, community contributions)
- Legitimate Interest: We have a legitimate business interest in fraud prevention, website security, and service improvement
6. DATA RETENTION
We retain your personal data only for as long as necessary to fulfill the purposes outlined in Section 4:
| Data Type | Retention Period |
| Pledge & Payment Information | 7 years (per Malaysian tax/financial regulations) |
| Contact Information | Duration of Campaign + 2 years (for support/dispute resolution) |
| WhatsApp Communications | 2 years after final Reward delivery |
| Community Contributions (Photos/Stories) | Indefinite (unless deletion requested) – used for production and archival purposes |
| Website Analytics Data | 12 months |
| IP Addresses & Browsing Data | 3 months |
After the retention period expires, we will securely delete or anonymize your personal data, except where we are legally required to retain it.
7. DATA SHARING & DISCLOSURE
7.1 Internal Sharing
Your personal data may be accessed by authorized Kotodama Lab Sdn Bhd staff members who need access to fulfill their roles (e.g., Campaign coordination, Reward fulfillment, customer support).
7.2 Sharing with Anti-Gravity Euphoria Sdn Bhd
We share limited personal data with Anti-Gravity Euphoria Sdn Bhd (the film’s IP rights holder) solely for:
- Generating Special Thanks credits
- Validating community contributions for production design
- Including contributor attributions in the film and promotional materials
Anti-Gravity Euphoria Sdn Bhd must adhere to equivalent data protection standards.
7.3 Third-Party Service Providers
We engage trusted third-party vendors to assist us in operating our Platform and delivering Services. These may include:
- Payment Processors: Process pledge payments securely (e.g., credit card, online banking)
- Email Service Providers: Send Campaign updates and communications
- WhatsApp Business API Provider: Deliver ticket redemption messages and updates
- Website Hosting Providers: Host and maintain www.kotodama.tokyo
- Analytics Services: Analyze website usage and performance
All third-party service providers are contractually bound to:
- Process data only as instructed by us
- Maintain equivalent data protection standards
- Not disclose your data to unrelated parties
- Delete or return data upon termination of services
7.4 Legal Disclosure
We may disclose your personal data if required by law, court order, or governmental authority, or if we reasonably believe disclosure is necessary to:
- Enforce our Terms & Conditions
- Protect our legal rights or the rights of others
- Prevent or investigate fraud or illegal activity
- Protect the safety and security of our Platform and users
7.5 No Sale of Personal Data
We do not sell, rent, lease, or trade your personal data to third parties for marketing purposes. Any sharing is strictly limited to the purposes outlined in this Policy.
8. DATA SECURITY
8.1 Security Measures
We implement industry-standard technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:
- Encryption: Payment information and sensitive data are encrypted using SSL/TLS protocols
- Access Controls: Data access is restricted to authorized personnel only
- Secure Storage: Data is stored on secure servers with firewalls and intrusion detection
- Regular Audits: We conduct periodic security reviews and vulnerability assessments
- Data Minimization: We collect only the minimum personal data necessary
8.2 Limitations
While we strive to protect your data, no security system is absolutely impenetrable. We cannot guarantee absolute security. You acknowledge that transmission of data over the internet carries inherent risks.
8.3 Breach Notification
In the event of a data breach affecting your personal data, we will notify affected individuals and relevant authorities as required by the PDPA without unreasonable delay.
9. YOUR RIGHTS AS A DATA SUBJECT
Under the PDPA, you have the following rights:
9.1 Right of Access
You have the right to request and obtain a copy of your personal data held by us. We will provide this information within 30 days of your written request.
9.2 Right of Correction
If your personal data is inaccurate, incomplete, or misleading, you may request correction or amendment. We will make corrections within 30 days or notify you if correction is not possible.
9.3 Right of Deletion
You may request deletion of your personal data in the following circumstances:
- Your data is no longer necessary for the original purpose
- You withdraw consent
- Your data has been processed unlawfully
- We have a legal obligation to delete
Exception: We may retain certain data (pledge records, payment information) where required by law or to fulfill our contractual obligations to you.
9.4 Right to Restrict Processing
You may request that we restrict processing of your personal data in certain circumstances, such as when disputing its accuracy.
9.5 Right to Withdraw Consent
If you have provided consent for specific processing activities (e.g., marketing communications, use of community contributions), you may withdraw consent at any time. This will not affect the lawfulness of processing prior to withdrawal.
9.6 Right to Lodge a Complaint
You have the right to lodge a complaint with the Personal Data Protection Commissioner (PDPC) if you believe we have violated your data protection rights.
Personal Data Protection Commissioner Contact:
- Website: www.pdpc.gov.my
- Email: enquiry@pdpc.gov.my
- Toll-free: 1-800-80-6622
10. EXERCISING YOUR RIGHTS
To exercise any of the rights outlined in Section 9, please submit a written request to:
Email: hello@kotodama.tokyo
Your Request Should Include:
- Your full name and Pledge ID (if applicable)
- Specific right you wish to exercise
- Detailed description of your request
- Proof of identity (copy of ID or passport)
- Preferred method of response
We will acknowledge receipt of your request within 7 days and respond substantively within 30 days, or notify you if additional time is needed.
11. CHILDREN’S PRIVACY
Our Platform and Campaign are not directed to children under 18 years old. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child under 18 without parental consent, we will delete such data immediately.
If you are a parent or guardian and believe we have collected data from your child, please contact us immediately at hello@kotodama.tokyo.
12. INTERNATIONAL DATA TRANSFERS
Personal data collected through our Platform is processed and stored primarily in Malaysia. However, some data may be transferred to or accessed by our third-party service providers located outside Malaysia.
By using our Platform, you consent to such transfers. We ensure that any international transfers are conducted in accordance with the PDPA and equivalent data protection standards.
13. COOKIES & TRACKING TECHNOLOGIES
13.1 What Are Cookies?
Cookies are small text files stored on your device that remember your preferences and interactions with our website.
13.2 Types of Cookies We Use
| Cookie Type | Purpose |
| Essential/Functional | Required for Platform functionality (login, pledge processing) |
| Analytical | Track user behavior and website performance (Google Analytics) |
| Preference | Remember your choices and settings |
| Marketing | Display relevant content and measure Campaign effectiveness |
13.3 Cookie Management
Most browsers allow you to control cookies through settings. You can:
- Accept or reject cookies
- Delete existing cookies
- Set preferences for specific websites
Note: Disabling essential cookies may impair Platform functionality.
13.4 Third-Party Cookies
We may use third-party analytics services (e.g., Google Analytics) that place cookies on your device. These services have their own privacy policies. We recommend reviewing their policies for details.
14. THIRD-PARTY LINKS & EXTERNAL WEBSITES
Our Platform may contain links to external websites operated by third parties. This Privacy Policy applies only to www.kotodama.tokyo. We are not responsible for the privacy practices of external websites.
We recommend reviewing the privacy policies of any third-party websites before providing your personal data.
15. MARKETING COMMUNICATIONS & OPT-OUT
15.1 Opt-In Communications
We may send you marketing communications about the Project, including:
- Campaign updates and milestones
- Project production news
- Promotional offers related to the film
These communications will only be sent if you have provided explicit consent.
15.2 Opting Out
You may opt out of marketing communications at any time by:
- Clicking the “Unsubscribe” link in any marketing email
- Sending a request to hello@kotodama.tokyo
- Replying “STOP” to WhatsApp marketing messages
Opting out will not affect transactional communications (e.g., Reward delivery notifications, ticket redemption details).
16. DATA PROTECTION OFFICER & CONTACT
For questions, concerns, or to exercise your data protection rights, please contact:
Kotodama Lab Sdn Bhd Email: hello@kotodama.tokyo Website: www.kotodama.tokyo
We aim to respond to all inquiries within 7 business days.
17. AMENDMENTS & UPDATES
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.
17.1 Notification of Changes
We will notify you of material changes by:
- Posting the updated Privacy Policy on our website
- Updating the “Last Updated” date at the top of this document
- Sending you a notification email (for material changes)
17.2 Continued Use
Your continued use of our Platform following notification of changes constitutes acceptance of the updated Privacy Policy.
18. COMPLIANCE WITH MALAYSIAN LAW
This Privacy Policy is designed to comply with:
- Personal Data Protection Act 2010 (PDPA)
- Personal Data Protection (General) Regulations 2010
- Malaysian Consumer Protection Act 1999
- Any other applicable Malaysian data protection and privacy laws
In the event of a conflict between this Privacy Policy and mandatory Malaysian law, the applicable Malaysian law will prevail.
19. ENTIRE AGREEMENT
This Privacy Policy, together with our Terms & Conditions, constitutes the entire agreement regarding your privacy and the collection and use of your personal data. It supersedes all prior agreements and understandings.
20. GOVERNING LAW & JURISDICTION
This Privacy Policy is governed by the laws of Malaysia. Any disputes arising from this Privacy Policy shall be resolved in the Malaysian courts.
By accessing www.kotodama.tokyo and pledging to the Campaign, you acknowledge that you have read and understood this Privacy Policy.
If you do not agree with our privacy practices, please do not use our Platform or participate in the Campaign.
Last Updated: October 2025
For the most current version of this Privacy Policy, visit www.kotodama.tokyo