TOKUGO | The Spatial Commerce Layer.

Last updated: 16.06.2026

This Privacy Policy explains how TOKUGO AI Ltd collects, uses, stores, shares, and protects personal data when you use our website, contact us, take part in a pilot, access a demo, use our platform, or interact with TOKUGO services.

TOKUGO is building the Spatial Commerce Layer — transforming cities into immersive discovery, shopping, and rewards experiences powered by Spatial AI, Augmented Reality, Location Intelligence, and real-time commerce technology.

We are committed to protecting your privacy and handling your personal data responsibly, transparently, and in accordance with UK data protection law, including the UK General Data Protection Regulation and the Data Protection Act 2018.

1. Who we are

This website and related services are operated by:

• Company name: TOKUGO AI Ltd

• Trading name: TOKUGO

• Company number: 16526298

• Registered office:
  71–75 Shelton Street, Covent Garden, London, UK, WC2H 9JQ

• Email: play@tokgo.ai

• Website: www.tokugo.ai

For the purposes of data protection law, TOKUGO AI Ltd is the “controller” of the personal data we collect and use, unless we state otherwise.

If you have any questions about this Privacy Policy or how we use your personal data, please contact us at:

• Email: [Insert Privacy Contact Email]

2. What this Privacy Policy covers

This Privacy Policy applies when you:

• Visit our website

• Contact us through a form, email, social media, event, or business introduction

• Request a demo or pilot

• Join a waiting list or newsletter

• Submit retailer, brand, partner, or investor information

• Use or test a TOKUGO app, demo, prototype, pilot, beta product, or platform feature

• Interact with TOKUGO location-based, AR, AI, rewards, wallet, or marketplace features

• Engage with TOKUGO as a business partner, retailer, brand, investor, supplier, adviser, contractor, or user

This Privacy Policy does not cover third-party websites, services, platforms, APIs, app stores, payment providers, wallet providers, map providers, analytics tools, or social media platforms that may have their own privacy policies.

3. Personal data we may collect

Depending on how you interact with TOKUGO, we may collect the following types of personal data.

3.1 Identity and contact data

This may include:

• Name

• Email address

• Phone number

• Job title

• Company name

• Business address

• LinkedIn profile or other professional profile

• Social media handle

• Investor, partner, or retailer details

3.2 Enquiry and communication data

This may include:

• Messages you send to us

• Forms you complete

• Meeting requests

• Demo requests

• Pilot applications

• Support requests

• Feedback

• Survey responses

• Call notes or meeting notes

• Communications with our team

3.3 Business, brand, and partner data

If you are a retailer, brand, venue, partner, supplier, or potential commercial partner, we may collect:

• Store names and locations

• Business contact details

• Product catalogue information

• Offer and promotion details

• Pricing and campaign information

• Brand assets

• Creative assets

• Logos and product images

• Campaign performance data

• Pilot participation details

• Commercial preferences

• Partnership status

• Letters of intent, proposals, or related business documents

3.4 Account and platform data

If you create an account or access a TOKUGO demo, pilot, dashboard, app, or restricted area, we may collect:

• Account login details

• User ID

• Profile details

• Preferences

• Saved offers

• Wallet activity

• Reward activity

• TOKUCoins or points activity

• Marketplace activity

• Redemption history

• Campaign dashboard activity

• Device sessions

• Security logs

• User settings

3.5 Location and spatial data

TOKUGO is designed around location intelligence and spatial commerce. Where you use location-enabled features, and where you give permission, we may collect:

• Approximate location

• Precise location

• Geofence interactions

• Nearby store or venue interactions

• AR discovery activity

• Map interactions

• Movement-based engagement events

• Offer unlock locations

• Redemption locations

• Spatial interaction data

• Location-based preferences

We will only collect precise location data where it is necessary for the relevant feature and where we have an appropriate lawful basis, such as your consent.

You can usually disable location sharing through your device settings, browser settings, or app permissions. Some TOKUGO features may not work properly without location access.

3.6 Device, technical, and usage data

We may collect:

• IP address

• Browser type and version

• Device type

• Operating system

• Mobile device identifiers

• App version

• Pages visited

• Links clicked

• Time spent on pages

• Referring website

• Session information

• Crash logs

• Diagnostic data

• Security logs

• Cookie identifiers

• Analytics data

3.7 AI personalisation and recommendation data

TOKUGO may use AI, automation, recommendation systems, and location intelligence to personalise discovery, offers, rewards, content, campaign insights, and user experiences.

This may involve processing:

• User preferences

• Favourite categories

• Saved offers

• Interaction history

• Location-based activity

• Reward activity

• Redemption behaviour

• Engagement patterns

• Device and usage signals

• Brand or retailer preferences

• Campaign performance signals

We do not use AI to make decisions that have legal or similarly significant effects on you without appropriate safeguards, human review where required, and a lawful basis.

3.8 Rewards, wallet, TOKUCoins, and marketplace data

If TOKUGO offers reward, wallet, TOKUCoins, voucher, digital asset, marketplace, or deal-trading features, we may collect:

• Reward balances

• TOKUCoins or points activity

• Voucher redemptions

• Wallet identifiers

• Transaction references

• Saved deals

• Marketplace listings

• Deal swaps or transfers

• NFT or digital asset references, if applicable

• Fraud prevention signals

• Security checks

If blockchain or wallet features are introduced, some transactions may be visible on public blockchain networks. Public blockchain records may not be controlled by TOKUGO and may not be capable of being deleted by us.

3.9 Marketing and event data

We may collect:

• Newsletter preferences

• Event attendance

• Campaign engagement

• Email open and click data

• Marketing consent status

• Unsubscribe requests

• Areas of interest

• Investor or partner communication preferences

3.10 Special category data

We do not intentionally collect special category personal data, such as:

• Health data

• Racial or ethnic origin

• Political opinions

• Religious beliefs

• Trade union membership

• Genetic data

• Biometric data used for identification

• Sexual orientation

• Sex life information

Please do not send us special category data unless we specifically request it and explain why we need it.

If future AR, computer vision, avatar, or biometric-style features are introduced, we will provide additional privacy information and obtain consent where required.

4. How we collect personal data

We may collect personal data directly from you when you:

• Complete a form

• Contact us by email or phone

• Book a meeting

• Request a demo

• Join a pilot

• Create an account

• Use our website or app

• Submit business, brand, or retailer information

• Interact with AR, map, reward, wallet, or marketplace features

• Attend an event

• Subscribe to updates

• Communicate with us on social media

We may also collect personal data automatically through:

• Cookies

• Analytics tools

• Device logs

• App usage data

• Location permissions

• Security monitoring

• Server logs

We may receive personal data from third parties, such as:

• Business partners

• Retailers and brands

• Event organisers

• Investor networks

• Professional contacts

• Public websites

• Social media platforms

• Analytics providers

• Technical service providers

• Payment or wallet providers, where applicable

5. Why we use personal data

We may use personal data for the following purposes:

• To operate and improve our website

• To respond to enquiries

• To arrange meetings, demos, and introductions

• To provide information about TOKUGO

• To assess pilot, partner, retailer, brand, investor, or supplier opportunities

• To create and manage accounts

• To provide access to demos, pilots, beta products, dashboards, or platform features

• To operate location-based, AR, map, rewards, wallet, and marketplace features

• To personalise offers, content, recommendations, and user experiences

• To help brands and retailers manage campaigns, offers, locations, and performance

• To measure engagement, footfall, redemptions, and campaign performance

• To detect fraud, misuse, abuse, security threats, or technical issues

• To comply with legal, regulatory, tax, accounting, and reporting obligations

• To send service updates

• To send marketing communications where permitted

• To improve our products, services, AI systems, and business strategy

• To protect our rights, property, users, partners, systems, and business

6. Our lawful bases for using personal data

Under UK data protection law, we must have a lawful basis for using personal data.

Depending on the situation, we may rely on one or more of the following lawful bases.

6.1 Consent

We may rely on consent where you have given us clear permission, for example:

• To receive certain marketing communications

• To use non-essential cookies

• To access precise location data

• To enable certain AR, personalisation, or location-based features

• To process certain optional data

• To participate in certain pilots or beta features

You can withdraw consent at any time. Withdrawing consent may affect access to some TOKUGO features.

6.2 Contract

We may use personal data where it is necessary to enter into or perform a contract with you or your organisation, for example:

• To provide access to a pilot, dashboard, demo, or service

• To manage partner, retailer, brand, or supplier relationships

• To process subscriptions, orders, invoices, or payments

• To deliver agreed campaign, platform, or production services

6.3 Legitimate interests

We may use personal data where it is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms.

Our legitimate interests may include:

• Developing TOKUGO

• Responding to business enquiries

• Building commercial relationships

• Improving our website and platform

• Measuring service performance

• Preventing fraud and misuse

• Protecting our systems

• Conducting B2B marketing

• Analysing campaign and product performance

• Developing pilot programmes

• Communicating with investors, advisers, partners, brands, and retailers

6.4 Legal obligation

We may use personal data where necessary to comply with legal obligations, including:

• Company law

• Tax law

• Accounting obligations

• Fraud prevention

• Regulatory compliance

• Data protection obligations

• Law enforcement requests where legally required

6.5 Vital interests

In rare cases, we may use personal data where necessary to protect someone’s life or physical safety.

7. Location data and AR features

Because TOKUGO is based on Spatial AI, AR, and Location Intelligence, location data may be central to some services.

We may use location data to:

• Show nearby offers, rewards, retailers, venues, and experiences

• Unlock location-based rewards

• Enable AR discovery

• Support map and spatial navigation features

• Measure campaign engagement and footfall

• Prevent fraud or abuse

• Improve location accuracy

• Personalise recommendations

Where required, we will request permission before collecting precise location data.

You may turn off location access through your browser, device, or app settings. If you turn off location access, some features may be limited or unavailable.

We do not intend to track precise location continuously in the background unless we clearly explain this and obtain the required permission.

8. AI personalisation, profiling, and automated processing

TOKUGO may use AI and automated systems to personalise experiences and improve commercial relevance.

This may include:

• Recommending offers based on location and preferences

• Prioritising nearby deals

• Suggesting rewards or categories

• Helping brands understand campaign performance

• Detecting fraud or suspicious activity

• Improving relevance of spatial commerce experiences

We may create user segments or profiles based on behaviour, preferences, location interactions, and engagement history.

We do not use solely automated decision-making that produces legal or similarly significant effects on individuals unless we have a lawful basis, provide required information, and implement appropriate safeguards.

You may contact us to ask about automated processing or to object to certain profiling where applicable.

9. Cookies and similar technologies

Our website may use cookies, pixels, tags, SDKs, local storage, and similar technologies.

These may be used to:

• Make the website work

• Remember preferences

• Measure website usage

• Understand visitor behaviour

• Improve performance

• Support security

• Support marketing and analytics

Strictly necessary cookies may be used without consent because they are needed for the website to function.

Where required by law, we will ask for consent before using non-essential cookies, including analytics, advertising, tracking, or personalisation cookies.

For more information, please see our Cookie Policy.

10. Marketing communications

We may send you marketing communications if:

• You have consented

• You have requested information

• You are an existing customer, partner, investor, or business contact and the law allows us to contact you

• We have another lawful basis to do so

You can opt out of marketing communications at any time by using the unsubscribe link in our emails or contacting us at [Insert Email].

We may still send non-marketing service messages, such as security notices, account updates, legal notices, pilot updates, or transactional communications.

11. Who we share personal data with

We may share personal data with trusted third parties where necessary, including:

• Website hosting providers

• Cloud infrastructure providers

• Analytics providers

• Email and CRM providers

• AI service providers

• Map and location service providers

• AR technology providers

• Payment providers

• Wallet or blockchain service providers, where applicable

• Fraud prevention and security providers

• Professional advisers, including lawyers, accountants, insurers, and consultants

• Brand, retailer, venue, or campaign partners where needed to operate offers or pilots

• Investors or potential investors as part of fundraising, due diligence, or corporate transactions

• Law enforcement, regulators, courts, or public authorities where legally required

We only share personal data where we have a lawful basis and appropriate safeguards.

12. International transfers

Some of our service providers may process personal data outside the UK.

Where personal data is transferred outside the UK, we will take steps to ensure it is protected in accordance with applicable data protection law, including using appropriate safeguards such as adequacy regulations, international data transfer agreements, or other approved mechanisms.

13. How long we keep personal data

We keep personal data only for as long as necessary for the purposes described in this Privacy Policy.

Retention periods may depend on:

• The type of data

• The reason we collected it

• Legal, accounting, or tax requirements

• Contractual obligations

• Pilot or partner status

• Security or fraud prevention needs

• Whether there is an ongoing relationship or dispute

As a general guide:

• Website enquiry data may be kept for up to 24 months

• Marketing data may be kept until you unsubscribe or withdraw consent

• Business contact and partner data may be kept for the duration of the relationship and for a reasonable period afterwards

• Pilot and campaign data may be kept for analysis, reporting, and legal purposes

• Account data may be kept while your account is active and for a reasonable period after closure

• Financial and transaction records may be kept for up to 6 years where required for tax, accounting, or legal purposes

• Security logs may be kept for a limited period unless needed to investigate misuse, fraud, or security incidents

We may anonymise data so it can no longer identify you. We may use anonymised data for analytics, research, product development, investor reporting, and business planning.

14. How we protect personal data

We use appropriate technical and organisational measures to protect personal data, which may include:

• Access controls

• Encryption where appropriate

• Secure cloud services

• Password protection

• Role-based access

• Monitoring and logging

• Security reviews

• Data minimisation

• Supplier due diligence

• Staff confidentiality obligations

• Backup and recovery measures

No website, app, platform, or online service can be guaranteed to be completely secure. You are responsible for keeping your account details, passwords, devices, and wallets secure.

15. Children

TOKUGO is not currently intended for children under 13.

If we launch services directed at children or young people, we will update this Privacy Policy and implement appropriate safeguards, including age-appropriate privacy information and parental consent where required.

If you believe a child has provided us with personal data without appropriate permission, please contact us.

16. Your data protection rights

Under UK data protection law, you may have the right to:

• Access the personal data we hold about you

• Ask us to correct inaccurate or incomplete data

• Ask us to delete your personal data

• Ask us to restrict how we use your data

• Object to certain processing

• Request transfer of your data to another provider

• Withdraw consent where we rely on consent

• Object to direct marketing

• Ask for human review of certain automated decisions, where applicable

• Complain to the UK Information Commissioner’s Office

To exercise your rights, contact us at:

• Email: [Insert Privacy Contact Email]

We may need to verify your identity before responding. We aim to respond to valid requests within one month, unless the request is complex or we are legally allowed more time.

17. Complaints

If you are unhappy with how we use your personal data, please contact us first so we can try to resolve the issue.

You also have the right to complain to the UK Information Commissioner’s Office.

• ICO website: www.ico.org.uk

• ICO helpline: 0303 123 1113

18. Third-party links and platforms

Our website or platform may link to third-party websites, services, social platforms, payment providers, wallet providers, app stores, maps, video platforms, or partner websites.

We are not responsible for the privacy practices of third parties.

You should read the privacy policies of any third-party service you use.

19. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

The updated version will be posted on this page with a new “Last updated” date.

If we make significant changes, we may notify you by email, website notice, app notice, or another appropriate method.

20. Contact us

For privacy questions or data protection requests, please contact:

• Company: TOKUGO AI Ltd

• Email: play@tokugo.ai

• Registered office: 71–75 Shelton Street, Covent Garden, London, UK, WC2H 9JQ

• Website: www.tokugo.ai