Privacy Policy

Cricket Tokai Netherlands B.V.
Effective Date: August 26, 2026
Last Updated: August 26, 2026

1. Who We Are (Data Controller)

This Privacy Policy applies to the Design Your Own platform operated by Cricket Tokai Netherlands B.V. ("we", "us", or "our"). We are committed to protecting and respecting your privacy in compliance with the General Data Protection Regulation (GDPR), local European data protection laws, and applicable US state privacy laws (including the California Consumer Privacy Act / CPRA).

Our Contact Details:

• Visiting Address: A.H.G Fokkerstraat 5, 9403 AM Assen, Netherlands
• Postal Address: P.O. Box 82, 9400 AB Assen, Netherlands
• Website: www.cricketlighters.com

If you have any questions about this privacy policy or how we handle your personal data, you can reach out to us using the contact form on our website.

2. What Personal Data We Collect and Why

We collect personal data that you voluntarily provide when you use the Design Your Own platform, as well as data gathered automatically via cookies or similar tracking technologies to ensure the platform functions correctly and securely.

A. Account and Authentication Data

To submit a design, you may need to authenticate yourself using an email-based account or your Google account. We process the authentication information needed to verify your account and may receive and store account information such as your name, email address, profile image or avatar, and an account identifier.

Authentication helps us prevent misuse of the platform, administer the service and gallery, associate submitted designs with the correct user, and contact participants or possible winners of Design Your Own competitions. We do not display your account information publicly or use it for marketing purposes.

B. Designs and Other Content You Submit

When you create or submit a design, we may collect and store:

• Your design, including uploaded artwork or images, generated design images and thumbnails, material choices, colours, and other design settings
• The title and description you provide for the design
• Information connected with the submission, such as its moderation, publication, or competition status
• Interactions with published designs, such as likes

Submitted designs are reviewed by Cricket Tokai before they are published in the gallery. If approved, a design may be displayed in the Design Your Own gallery and used as described in the Terms and Conditions, including on Cricket websites and social media platforms. Cricket Tokai decides which designs are published and may remove a published design or block a user from submitting designs where necessary.

C. Business Enquiries, Quote Requests, Feedback and Reports

If you use the platform to send us a design, request a quote, make a business enquiry, provide survey feedback, report a design, or request removal of a design, we may collect:

• Contact and identification details, such as your name, email address, phone number, and country or location
• Information about you or the organisation you represent, such as user type, business name, and social media channel
• Details about your enquiry, interests, requested products or services, or submitted design
• Business or commercial information you choose to provide, such as expected order quantities
• The content of your message, report, or feedback, including survey responses or ratings, and any additional information or files you submit
• Your communication and consent preferences

Purpose and Legal Basis (EU / GDPR): We use this information to operate and administer the Design Your Own platform, authenticate users, prevent misuse, review and publish designs, manage the gallery and competitions, respond to questions, process submissions, reports, feedback and requests, route enquiries to the correct regional department, and communicate with you effectively. The legal basis for this processing is our legitimate interest in operating the platform and managing customer and business service enquiries properly and efficiently.

Purpose (US Residents): We collect this information to provide and administer the platform, fulfil your requests, process design submissions, provide customer support, and maintain business communications. We do not "sell" or "share" (as defined under US state privacy laws) this information to third parties for cross-context behavioral advertising.

D. Cookies and Website Analytics

Our platform uses cookies and similar tracking technologies to distinguish you from other users, secure the platform, and improve your experience.

• We use analytics and tag-management tools, including Google Tag Manager and Vercel Analytics, to collect standard internet log information and visitor behavior patterns.
• Legal Basis (EU / GDPR): The legal basis for non-essential tracking cookies is your consent, which is gathered via our cookie banner when you first visit the platform. You can manage or withdraw your consent at any time via our cookie controls or browser settings.
• Notice at Collection (US Residents): Depending on your jurisdiction, the use of analytics cookies may be classified as "sharing" or targeted advertising. You have the right to opt out of such tracking by using our cookie preference center or broadcasting a recognized Global Privacy Control (GPC) signal.

3. How We Share Your Data

As part of the Tokai international group of companies, your data may occasionally be shared with internal administrative departments or affiliated corporate entities strictly on a "need-to-know" basis to operate the platform, handle your requests, administer competitions, or manage group compliance.

• We do not sell, rent, or trade your personal data to external third parties.
• Trusted service providers, such as authentication, IT hosting, platform administration, or analytics providers, may process data on our behalf under strict Data Processing Agreements (DPAs).
• Approved designs may be displayed publicly as described above and in the Terms and Conditions. Your account details are not displayed publicly with a design.
• International Transfers: When personal data is transferred outside the European Economic Area (EEA) or your home country to affiliated entities or service providers, we ensure appropriate safeguards are in place, such as European Commission Standard Contractual Clauses (SCCs) or equivalent legal mechanisms.

4. Data Security and Retention

• Security: We implement appropriate technical and organizational security measures to protect your personal data and submitted designs against accidental loss, unauthorized access, destruction, or alteration.
• Rejected designs: A rejected design will be cleared and removed from the platform's server within 7 days.
• Approved designs: An approved design may be stored for the lifetime of the platform and for any additional period required to meet legal obligations.
• Account and enquiry data: We retain personal data only for as long as necessary to administer the platform, gallery, submissions or competitions, or to fully resolve your enquiry, report, feedback or request. After that, the data is securely archived or deleted in accordance with statutory retention periods.

5. Your Privacy Rights

Depending on your place of residence, you have statutory rights regarding your personal data:

• European Users (GDPR): You have the right to request access, correction, or deletion ("right to be forgotten") of your data, restriction of processing, data portability, and the right to withdraw consent at any time. You also have the right to lodge a complaint with a supervisory authority (such as the Autoriteit Persoonsgegevens in the Netherlands or your local EU data protection authority).
• US State Residents (e.g., California / CCPA): You have the right to know what personal information is collected, request deletion of your personal data, correct inaccurate data, and opt out of the "sale" or "sharing" of personal information (if applicable). We do not discriminate against you for exercising your privacy rights.

You may also ask us to remove a design you submitted from the gallery, or report a published design that may violate the law or third-party rights.

To exercise any of these rights or make a design removal request, please reach out to us using the contact details or contact form on our website.

6. Updates to This Policy

We may update this privacy policy from time to time to reflect changes in our operations, technologies, or legal obligations. The latest version will always be posted directly on this page.