Legal

Effective Date: Thursday, 12 June, 2025

1. Preamble and Legal Scope

1.1 Organizational Framework and Applicability

Tukio Images and its parent company, Tukio Media Limited, based in Kenya (collectively referred to as "Tukio Images"), are committed to protecting your privacy and upholding fair terms of service. This comprehensive legal document governs your use of all Tukio Images websites, associated digital platforms, applications, and licensing services.

By accessing or using our websites, registering an account, or licensing content, you agree to the practices and terms outlined in this document. Content syndicated, distributed, or aggregated through partner networks, including StringersHub and its global affiliates, remains subject to the applicable licensing constraints and privacy frameworks established by those primary rights holders.

1.2 Governance and Regulatory Alignment

Tukio Images operates under the legal framework of the Republic of Kenya, including the Data Protection Act of 2019 and the Copyright Act. Where applicable, our operations also align with international data protection standards, including:

• European Union General Data Protection Regulation (EU GDPR)

• UK Data Protection Act

• State privacy statutes in the United States

This policy outlines our standards regarding data collection, operational use, cross-border transfers, intellectual property, and user choices.

2. Collection of Personal Data

2.1 Direct Information Provided by You

We collect personal information you provide directly to us during your interactions with our platforms, such as when creating an account, purchasing a license, subscribing to a service, or contacting customer support.

• General Personal Data: Full name, email address, postal address, telephone number, fax number, organizational affiliation, and demographic details.

• Financial Data: Billing addresses, credit card numbers, and payment verification details collected by our authorized payment processors or us.

2.2 Individuals Featured in Editorial Content

In the course of our journalistic, editorial, and public-interest operations, we collect, create, process, and publish media (photographs, video clips, audio recordings) depicting individuals who are not direct platform users. This content captures public events, news incidents, and matters of societal interest. We process this personal data strictly for journalistic, literary, and public-interest purposes in accordance with applicable statutory privacy exemptions.

2.3 Generative Artificial Intelligence Submissions and Prompts

Certain platform services allow you to generate results from text prompts or uploaded files (defined as User Content). These AI tools are strictly not designed or intended to process personal data.

Important Restriction: You are strictly prohibited from including any personal data, personal identifiers, or identifiable faces in any AI prompt or file upload.

• Automated Controls: We employ automated prompt-blocking controls to discourage references to public figures or identifiable private individuals. These systems are not exhaustive and do not constitute pre-screening.

• Breach Policy: Submitting personal data via generative AI tools constitutes a material breach of our Terms of Use. Tukio Images reserves the right to block, delete, or remove non-compliant content and restrict account access.

2.4 Information Collected Automatically

When you navigate our websites, our systems automatically log technical and usage details using cookies, pixel tags, and web servers:

• Internet Protocol (IP) address

• Operating system and browser type/language

• Access timestamps and referral website addresses

• Navigational activity (pages viewed, links clicked)

2.5 Third-Party Sources and Cross-Device Tracking

We supplement direct data with insights from third-party sources (e.g., demographic data brokers, public social media profiles, IP geolocation providers, co-branded marketing partners).

We also engage in cross-device data collection, using statistical analysis to link multiple devices associated with the same individual or household, thereby delivering interest-based advertising and optimizing campaign performance.

3. Operational Use of Personal Data

3.1 Primary Business Purposes

We process personal data to:

• Process purchases, issue content licenses, and manage account registrations.

• Secure system infrastructure and troubleshoot software errors.

• Provide customer support and analyze usage patterns to refine platform search functions.

• Display tailored digital communications and advertisements aligned with your interests.

3.2 Artificial Intelligence Meeting Companion Tools

To enhance internal collaboration and record-keeping, Tukio Images utilizes AI companion tools to record, transcribe, and summarize selected calls and online video meetings.

• Data Scope: Audio recordings, transcripts, and summaries are secured in encrypted internal databases solely for workflow management, quality assurance, employee training, and meeting follow-ups.

• Consent: Participants receive automated notifications before recording and may decline consent, which prevents the tool from activating.

3.3 Marketing Communications and Preferences

We process data to send essential administrative updates, transaction invoices, security alerts, and customer support notices. Subject to your preferences, we may also send promotional communications regarding media collections, platform features, and special events. You retain the right to unsubscribe from promotional emails at any time.

3.4 Payment Processing and Account Updater Services

Financial transactions are processed securely by authorized payment partners. To prevent service interruptions on recurring subscriptions, we participate in automated account updater services provided by card networks to maintain current credit card numbers and expiration dates.

4. International Data Transfers and Storage

4.1 Global Storage Infrastructure

Personal data collected by Tukio Images may be hosted and processed in Kenya, the United States, or any country where Tukio Images, its parent company, affiliates, or service providers maintain facilities. Primary cloud data centers are located in the United States for optimal performance and redundancy.

4.2 Cross-Border Transfer Mechanisms

When transferring personal data internationally from the EEA, UK, or Switzerland to non-adequate jurisdictions, we employ valid transfer mechanisms:

• European Commission Standard Contractual Clauses (SCCs)

• Corporate transfer contracts

• Statutory Kenyan data protection requirements

We align operations with the EU-U.S. Data Privacy Framework (DPF), the UK Extension, and the Swiss-U.S. DPF principles: Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity, Purpose Limitation, Access, and Recourse.

4.3 Regulatory Oversight and Dispute Resolution

Tukio Images is subject to the regulatory powers of bodies including the Kenya Office of the Data Protection Commissioner (ODPC) and the U.S. Federal Trade Commission (FTC).

User Jurisdiction	Dispute Escalation Contact / Authority
Global / Unresolved Disputes	JAMS (Alternative Dispute Resolution under JAMS International Mediation Rules)
United Kingdom Residents	Information Commissioner's Office (ICO)
European Union Residents	National Data Protection Supervisory Authority
DPF Panel Arbitration	Data Privacy Framework Panel (under specific statutory conditions)

5. Sharing, Retention, and Security of Personal Data

5.1 Onward Data Sharing and Disclosure

Tukio Images does not sell, rent, or trade your personal data to unaffiliated third parties. Data is shared only under the following conditions:

1. Consent & Fulfillment: With your explicit consent or to complete licensing transactions and asset deliveries.

2. Corporate Group: Shared with our parent company, Tukio Media Limited, regional subsidiaries, and appointed regional distribution networks.

3. Third-Party Vendors: Shared with vetted service providers (web hosting, cloud storage, payment gateways, legal auditors) strictly bound by confidentiality contracts.

4. Corporate Transactions & Legal Obligations: In connection with mergers, acquisitions, or restructuring, or as required by law, subpoena, or valid court order.

5.2 Data Retention Policies

Personal data is retained only as long as necessary for operational, legal, and tax requirements. Because digital content licenses grant long-term or perpetual rights, Tukio Images retains transaction histories, download logs, and license certificates for the full duration of underlying copyrights to verify rights clearance and defend against legal claims.

5.3 Data Security Protocols

We maintain physical, technical, and administrative safeguards—including Transport Layer Security (TLS) and Secure Sockets Layer (SSL) encryption—to protect your data. Users remain responsible for safeguarding account credentials and maintaining secure passwords.

6. Cookies, Tracking Technologies, and Analytics

6.1 Cookie Functionality and Deployment

We utilize cookies, pixel tags, web beacons, and local browser storage to manage platform operations, save lightboxes and shopping carts, retain search filters, and authenticate login sessions.

6.2 Analytics and Targeted Advertising

We partner with web analytics and ad networks (such as Google, Amazon, and Meta) to monitor site traffic and display targeted commercial content across third-party websites. Google Analytics features used include Demographics and Interest Reporting.

6.3 Cookie Management and Opt-Out Options

You can manage or disable cookies via your web browser settings. Disabling cookies may impair platform functionality. Because browser "Do Not Track" (DNT) standards remain unstandardized across the industry, our sites do not currently alter data collection practices upon detecting DNT headers.

7. Legal Bases, Privacy Rights, and Interactive Features

7.1 Legal Bases for Processing

Under European, British, and Kenyan privacy frameworks, processing is based on:

• Contractual Necessity: Performing licensing agreements and services.

• Legal Obligation: Satisfying statutory tax and corporate compliance duties.

• Legitimate Interests: Safeguarding system security, quality assurance, research, and marketing.

• Consent: Where applicable, which can be withdrawn at any time.

7.2 Consumer Privacy Rights

Depending on your jurisdiction, you may hold rights to access, port, correct, delete, or restrict the processing of your personal data.

Submitting Requests: Written requests can be submitted to our privacy team. We will verify your identity and respond within 30 days.

7.3 Public Forums and Interactive Services

Information posted in public message boards, blogs, or file-sharing areas (Interactive Areas) becomes public data. Tukio Images is not responsible for personal data voluntarily disclosed in these public areas.

7.4 Model Releases and Children's Privacy

• Model Releases: Personal data and likeness processing for photoshoot participants governed by explicit Model Releases are handled alongside applicable copyright law.

• Minors: Our services are intended strictly for adult professionals. We do not knowingly collect data from children under 13 (U.S.) or 16 (EU). Accounts found to belong to underage individuals will be deleted immediately.

8. Terms of Use and Contact Information

8.1 License Terms and Account Conduct

All content, branding, software, and media on Tukio Images platforms are protected by Kenyan and international intellectual property laws. Users are granted limited, non-exclusive, non-transferable rights strictly per their download agreement. Sublicensing, reselling, or redistributing standalone media assets is strictly prohibited.

8.2 Updates to Policy

Tukio Images reserves the right to modify this legal policy at any time. Updated documents will feature a revised date, and material changes will be announced via platform notices or direct email.

8.3 Contact Details

For privacy inquiries, legal questions, or concerns:

• Email: privacy@tukioimages.com

• Postal Address (Kenya): Tukio Media Limited, Attention: Privacy Office, Nairobi, Kenya.