Privacy policy

1. Who We Are

Tornado Publicity is a music publicity service brand operated by Tugboat Records Inc. (Tugboat Records 株式会社) (“we”, “us”, or “our”), located at 1F, 1-33-6 Ebisu-Nishi, Shibuya-ku, Tokyo, Japan 150-0021. Tugboat Records Inc. is the business operator responsible for handling your personal information and the data controller for the purposes of applicable data protection laws, including Japan’s Act on the Protection of Personal Information (“APPI”).

This Privacy Policy explains how we collect, use, and disclose your personal information when you visit our website, make a purchase, engage our publicity services, or communicate with us (together, the “Services”). Our website is powered by Shopify. If this Privacy Policy conflicts with our Terms of Service regarding the handling of personal information, this Privacy Policy controls.

2. Personal Information We Collect

Depending on how you interact with us, we may collect:

Contact details: name, company/label name, artist name, address, billing and shipping address, phone number, email address.
Financial and transaction information: orders, invoices, payment confirmations and related details. Card payments are processed by third-party payment providers (e.g., Shopify Payments, Stripe); we do not store full payment card numbers.
Account information: username, password, preferences and settings, if you create a customer account.
Campaign materials: audio files, press kits, artwork, biographies, links, and other promotional materials and communications you provide for your campaign.
Communications with us: the content of emails, messages, and inquiries.
Device and usage information: IP address, browser type, device identifiers, time zone, and how you interact with the website, collected through cookies and similar technologies.

3. Sources of Personal Information

We collect personal information directly from you, automatically through the Services (cookies and similar technologies), from our service providers, and from our partners or other third parties.

4. How We Use Personal Information (Purposes of Use)

We use personal information for the following purposes:

Providing the Services: to plan, execute, manage, and report on publicity and media promotion campaigns; to process orders, payments, and invoices; to create and manage customer accounts.
Campaign distribution: Targeted delivery of press releases, music, and promotional assets to relevant media outlets, DSPs, and industry partners for your campaign.
Communicating with you: to respond to inquiries, send order confirmations, campaign updates, and coverage reports, and provide customer support.
Improving the Services: to analyze website usage, improve our website and services, and develop new services.
Marketing and advertising: to send promotional communications by email, and, if we use such services in the future, to show you online advertisements, including based on your activity on our website.
Security and fraud prevention: to authenticate accounts, detect and prevent fraud and unauthorized activity, and secure our Services.
Legal reasons: to comply with laws and legal processes, and to establish, exercise, or defend legal claims.

5. How We Disclose Personal Information

We do not sell your personal information for money. We may disclose it to:

Media contacts and industry partners: Targeted media outlets, digital service platforms (DSPs), and industry partners who receive campaign materials and artist-related information solely for publicity and campaign execution purposes. These recipients may be located outside Japan.
Service providers: Shopify (hosting, store operations), payment processors (e.g., Stripe), analytics providers (e.g., Google Analytics), email and communication tools, and cloud storage providers, who process information on our behalf.
Marketing and advertising partners: if we use targeted advertising in the future, we may share certain online activity data with advertising platforms. Depending on where you live, this may be considered “sharing” or “sale” under applicable law, and you may have the right to opt out (see Section 9).
Professional advisers: lawyers, accountants, and other advisers, as needed.
Business transfers: in connection with a merger, acquisition, or sale of assets.
Authorities: where required by law or to protect our rights or the rights of others.
Others with your consent or at your direction.

6. Relationship with Shopify

Our Services are hosted by Shopify, which collects and processes personal information about your use of the Services to provide and improve them. We also use certain Shopify enhanced features that use data from your interactions with our store, other merchants, and Shopify. In those cases, Shopify is responsible for that processing, including responding to your rights requests. See the Shopify Consumer Privacy Policy and the Shopify Privacy Portal for details.

7. International Transfers

We are based in Japan, and our service providers and campaign recipients may be located in other countries, including Canada, the United States, and countries in Europe and Asia. Your information may therefore be transferred to, stored, and processed outside the country where you live.

For users in Japan: where we provide personal data to a third party in a foreign country, we do so with your consent, or where the recipient has put in place systems conforming to the standards required under the APPI, or where otherwise permitted by the APPI. On request, we will provide information about the foreign country concerned, its personal information protection system, and the measures taken by the recipient.
For users in the EEA and the UK: where we transfer personal information outside the EEA or the UK, we rely on recognized mechanisms such as an adequacy decision (Japan benefits from an EU and UK adequacy decision for certain data) or the European Commission’s Standard Contractual Clauses or the UK equivalent.

By placing an order or submitting campaign materials, you acknowledge that your information may be provided to recipients in foreign countries as described above for the purpose of your campaign.

8. Security and Retention

Security. We take necessary and appropriate measures to prevent unauthorized access to, and loss, leakage, or damage of, personal information, including [access restrictions limited to authorized staff, use of password-protected and encrypted services, and supervision of service providers]. No security measure is perfect, and we cannot guarantee absolute security.

Retention. We keep personal information only as long as necessary for the purposes described in this policy. Our general guidelines are:

Accounting and tax records (orders, invoices): [7 years], as required by Japanese law.
Campaign materials and campaign-related communications: [12 months] after the campaign ends, then deleted or archived, unless you ask us to delete them sooner.
Customer account data: until you request deletion or the account becomes inactive for [3 years].
Marketing subscription data: until you unsubscribe.
Website analytics and cookie data: according to the settings of each provider.

We may keep information longer where needed to comply with legal obligations, resolve disputes, or enforce agreements.

9. Your Rights and Choices

Depending on where you live, you may have the right to request access to, correction of, deletion of, or suspension of use of your personal information, and to request that we stop providing it to third parties. You may also have the rights below. These rights are not absolute and may be limited by law.

Access / Know, Correct, Delete.
Portability: to receive a copy of your information and ask us to transfer it to another party in certain circumstances.
Opt out of sale, sharing, or targeted advertising. If we use targeted advertising, you can opt out through [opt-out link]. We treat the Global Privacy Control signal as an opt-out request where required by law. We do not recognize other “Do Not Track” signals.
Marketing communications: you can unsubscribe at any time using the link in our emails. We may still send you non-promotional messages, such as order and account notices.
If you live in the UK or EEA: you may also object to or request restriction of processing, and withdraw consent at any time (without affecting prior processing).

How to make a request. Contact us using the details in Section 13. We will verify your identity before responding, and will respond within a reasonable period, and within the timeframes required by applicable law. You may use an authorized agent, who must provide proof of authorization. We will not discriminate against you for exercising your rights. Fees may apply where permitted by law (for example, for disclosure requests under the APPI).

10. Cookies and Analytics

We use cookies and similar technologies to operate the website, remember your preferences, analyze traffic (e.g., Google Analytics), and, if enabled in the future, support advertising. You can control cookies through your browser settings and, where available, our cookie banner.

11. Third-Party Websites and Children

Our Services may link to third-party websites, which have their own privacy policies; we are not responsible for them. Our Services are not intended for children, and we do not knowingly collect personal information from children under the age of majority in their jurisdiction. If you believe a child has provided us with personal information, contact us and we will delete it.

12. Complaints and Changes

If you have a complaint about how we handle your personal information, please contact us. Depending on where you live, you may also lodge a complaint with your local data protection authority (in Japan, the Personal Information Protection Commission; in the EEA, your local supervisory authority).

We may update this Privacy Policy from time to time. We will post the revised version on this website, update the “Last updated” date, and provide notice where required by law.