Privacy Policy

The SwincaCoin Privacy Policy (hereinafter referred to as this “Policy”) applies to the information collected from users (hereinafter referred to as the “User”) of the Service (defined in Article 1(2)) through Swinca Coin’s official website ( : hereinafter referred to as this “Website”), which is managed and operated by TimeTicket GmbH (hereinafter referred to as the “Company”). Upon the User’s agreement to this Policy, the User shall be deemed to have given a voluntary and express consent to the subject matters of the User’s consent stipulated in this Policy (including, without limitation, the purposes of processing of the Collected Information (defined in Article 1) and transfer of the Collected Information to third countries).

1. Collection of Information

The Company collects the following information in order to achieve the purposes defined in Section 3 (items (1) and (2) will be collectively referred to as the “Collected Information” hereinafter).
  1. Information collected from the User by the CompanyIn this Policy, “Personal Information” means “personal data” as defined in GDPR (REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC(General Data Protection Regulation)) and the Company processes the following Personal Information in particular.
    1. Name, date of birth, sex, occupation, or other information that identifies a specific individual;
    2. Information such as addresses, phone numbers, account information (e-mail addresses, passwords and the like.) and nicknames connected with and used for specific Personal Information;
    3. Credit card information;
    4. Hobbies, family composition, age and other attributes of individuals that are integrated with Personal Information;
    5. Information collected to confirm the User’s identities; and
    6. Name, nickname, e-mail address, Facebook ID, date of birth, gender, profile image, friend information on Facebook, and other information registered on the User’s Facebook in the case where if the User approved the use of Facebook Connect on this Website and the User entered Facebook ID and password therein.
  2. Information collected by the Company relating to the use of the Service (meaning the service provided on this Website; the same shall apply hereinafter) by UserThe following information relating to the use of the Service shall be collected regardless of whether or not such information falls under the category of Personal Information.
    1. Information related to the use of the Service and the browsing of this Website, including the contents of the Service that the User have used, the date and frequency of use, and the User’s online behavior when using the Service (including information on the use of Cookie information, access logs and the like, information regarding the terminal used by the User, location information, and information regarding the User’s communications, including IP address, browser information, and browser language and the like.);
    2. Equipment information such as individual identification information of a terminal;
    3. Posts, photographs, videos, comments, transaction messages, evaluations and other information published or sent to the Service by the User; or
    4. Information regarding the User’s settlement status with the Service.

2. Collection Methods and Management of the Collected Information

The Company collects the Collected Information from the User who uses this Website by the following methods.
  1. Inputted directly by the User on this Website;
  2. Provided by the User to Our group (meaning Global Way, Inc. and Time Ticket, Inc.[AZX1] ; the same shall apply hereinafter) with and by e-mail, mail, document, telephone and the like (the Company and Our group would record all calls with the User to improve our reception service quality and the like.);
  3. Collected through the use of the Service or access to the Website by the User; or
  4. Collected indirectly through business partners and third parties (including collecting the User’s registration information from Facebook in the case where the User enter the User’s Facebook ID and password to use the Facebook Connect on this Website)
People, who engages in the management and use of the Collected Information, shall take all necessary precautions to ensure that the Collected Information is securely managed and pay adequate attention to avoid unauthorized access to the Collected Information, loss, leakage and manipulation, and make an effort for its work.

3. Purpose of Use and Legal Background of the Collected Information

The Company may collect and use the Collected Information relating to the User set forth in Article 1 above in cases where (i) the Company obtains the express prior consent by the User, (ii) it is necessary for the performance of the contract or for the procedure to execute the contract between the User and the Company, (iii) it is necessary to comply with the legal obligations applicable to the Company and Our group, (iv) it is necessary to protect the vital related interest of the User or of other natural person, or (v) it is necessary to provide the Service to the User sufficiently, or the Company, Our group or other third parties have the legitimate interest set forth below (3), (4), from (6) to (11) for the following purposes.
  1. To contact regarding the various matters and provide information relating to this Website;
  2. To provide this Website in a form that is best tailored to the User;
  3. To investigate and analyze the situation of utilization of the Service;
  4. To make improvements and further developments to the Service to ensure the User’s satisfaction;
  5. To handle the User inquiries;
  6. To conduct research and development for the purposes of social implementation;
  7. To broadcast or display advertisements of the Company or third parties;
  8. To broadcast or display information regarding products available in the services provided by the Company or third parties;
  9. To provide the Service safely and normally, and to prevent unauthorized usage (including preventing the unauthorized use such as spam and unauthorized access, and measures taken in the case that unauthorized access occurs);
  10. To solve troubles with respect to the operation of the Service; and
  11. To create statistical data in a form that makes it impossible to identify individuals.

4. Provision of the Collected Information to Third Parties

The Company provides the Collected Information to the following third parties (including those located outside EU). “EU” means the European Union, including Iceland, Liechtenstein and Norway under the European Union Member States and the European Economic Area Agreement. The same applies hereafter.
  1. Our group;
  2. Professional advisors such as accountants and lawyers and the like;
  3. Public institutions; or
  4. Business partners

5. Transfer of the Collected Information to Third Countries

  1. The Company may, to the extent necessary for pursuing the purposes of use specified in Article 3 above, transfer and process the Collected Information regarding the User to countries outside EU, including Japan. The User may not have the right as a data subject same as that under GDPR in countries outside EU, and the Company shall take steps regarding the User’s Collected Information in accordance with the Applicable Privacy Laws (meaning privacy laws applicable to the Company, including GDPR, and domestic laws related thereto of relevant countries; the same shall apply hereinafter), by means of the execution of standard contractual clauses under GDPR and the like.
  2. Upon the User’s consent to this Policy, the User shall be deemed to have given a voluntary and express consent to the transfer of the Collected Information to third countries set forth in this Article 5.
  3. Japan, to which the transfer stipulated in this Article 5 is made, has obtained an adequacy decision by European Commission

6. Usage of Cookie and the like

User may choose whether or not Cookie is used. Many web browsers automatically enable the usage of Cookie, but the User can disable them in its browser setting. Please confirm the following points:
  1. If the User disables Cookie, it would be possible that this Website may not function properly or that advertisement setting requiring Cookie may not work; and
  2. The Company automatically receives information of the Cookie regarding the User, browsed advertisements and pages, and various other information regarding the User’s usage environment and the like from the browser and such information is saved in servers and used to improve convenience for accessing this Website, and used for the security such as preserving and protecting sessions.

7. Google Analytics

The Company uses Google Analytics, provided by Google, on this Website to investigate and analyze the situation of utilization and the like of this Website. With respect to the explanation regarding the Terms of Use of the Google Analytics, please refer to Google Analytics’ website and, with respect to the explanation regarding Google’s Privacy Policy, please refer to Google’s website. Google Analytics Terms of Service : Google Privacy Policy : Google Analytics uses the systems such as Cookie and the like to grasp User’s situation of utilization and the like. User who does not want Google Analytics to use its data should use the Google Analytics opt-out add-on provided by Google. Google Analytics opt-out add-on :

8. Management and Security of the Collected Information

The Company securely stores the Collected Information collected from the User in servers under an environment inaccessible to other general users, and strives to prevent unauthorized access, loss, destruction, manipulation, or leakage of data.

9. Information from Minor User

The Company protects the Collected Information collected from minor User at the same level of for adults. If any User under the age of 16 uses the Service, it shall make sure to obtain the guardian’s consent to this Policy or to give the consent to this Policy under the guardian’s permission thereto.

10. Amendments and Improvements to this Policy

The Company works on the improvement of this Policy appropriately as specified below:
  1. This Policy may be updated in accordance with the amendment to laws and regulations or the necessity for the Company’s business. The Company would notify the User in the event that amendments are made to this Policy.
  2. Please be sure to check the latest version of this Policy when accessing this Website.

11. Disclosure, Correction, and Suspension and the like of Use of Stored Personal Information

In cases where the Company stores the Collected Information , the User may request the Company to access to the Collected Information, disclosure, correction, or suspension of use, deletion, restrictions on processing, objections to processing, and exercise of data portability rights with respect to the Personal Information, and the Company would respond to that request appropriately in accordance with GDPR. When the User requests the disclosure of their stored personal information and the like, the User may do so in accordance with the procedures separately designated by the Company, unless it is manifestly unfounded or excessive, in particular because of their repetitive character, it is unable to confirm the identity of the User, or other cases where the Company may be able to refuse to respond to the request under the GDPR.

12. Withdrawal of Consent

For the processing of the Collected Information based on the User’s consent, the User shall have the right to withdraw the consent for the Collected Information at any time.

13. Lodgment of Complaint to Supervisory Authority

In addition to the aforementioned rights, the User may lodge a complaint to a supervisory authority at any time. However, the Company appreciates a notification to the Company prior to contacting the supervisory authority, so that the Company may have the opportunity to respond to the complaint of the User.

14. Storage Period

The Company shall store the Collected Information of the User to the extent necessary for the purpose of processing the data, and delete the Collected Information when the storage becomes unnecessary for such processing purpose.

15. Necessity of Provision of the Collected Information

Since the Collected Information to be provided by the User are necessary for the Company to provide the Service, the Service may be unavailable to the User that does not provide the data.

16. Inquiries (the Controller’s contact)

Please send the inquiries regarding this Policy to the person of the Company in charge described in below.

Smart Win Capital LTD

17. General Provisions

In the event of conflict between the Applicable Privacy Laws and any provision of this Policy, the provision shall be replaced by a provision which has the same meaning that reflects the original intention, to the maximum extent permitted by laws. In that case the remaining provision hereof shall continue to be applied without change.