Privacy Policy

General information about processing your data

We are committed to protect your personal data. We would therefore like to inform you below about which data we process in accordance with the relevant data protection laws and for what purposes. Personal data (hereinafter referred to as “data”) is all data that relates to you as a person, such as your name, address, email address or account number. 

Controller according to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is Tomokachi, Cyprus. You may contact our Data Protection Officer , by email at 

Source and types of data

We collect several different types of data from you for various purposes to provide and improve our service to you. These are: 


  • Name and Contact Data: Your first name and last name, your email address, postal address and your phone number. 
  • Transaction Data: Your wallet addresses, your Tomokachi address and other data required for transferring Tomokachi(TMK).  
  • Usage Data: These may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, browser language, country of origin of the IP address, content of the request (specific page), browser settings, amount of data transferred, the web page from which the request is made, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. 

Legal bases for processing your data

When processing your personal data, we may rely on one or more of the following legal bases (or other available legal grounds), depending on the circumstances: 


  • Contractual Necessity (Art. 6 para. 1 lit. (b) GDPR) – We may process your personal data where such processing is necessary in connection with any contract that we have with you, or to take necessary steps to enter into a contract with you at your request. 
  • Legitimate Interests (Art. 6 para. 1 lit. (f) GDPR) – We may process your personal data where we have a legitimate interest in such processing for managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights or freedoms. 
  • Legal Requirements (Art. 6 para. 1 lit. (c) GDPR) – We may process your personal data where such processing is required by applicable law. 
  • Consent (Art. 6 para. 1 lit. (a) GDPR) – We may process your personal data where we have obtained your consent to the processing. 

Period of storage of data

It is our policy is to store your personal data only for as long as is necessary to fulfill the purposes for which we collected such personal information, including for the purposes of satisfying any professional, legal, accounting or reporting requirements to which we are subject. To determine the appropriate retention period for personal information, we consider the scope, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we collected and processed your personal information and whether we can achieve those purposes through other means, and any applicable legal and professional requirements. 

Recipients or categories of recipients

Your data will not be disclosed to third parties except where it is necessary for fulfillment of our obligations to you, where you have given your Consent, where we are obliged or permitted to do so by law or where we make disclosures that are otherwise consistent with the uses described in this privacy policy. 

In part, we use external service providers to process your data. These have been carefully selected and commissioned by us, are bound by our instructions and are regularly inspected by us. 

Insofar as our service providers or partners are based in a country outside the European Union (EU) and the European Economic Area (EEA), we inform you below about the consequences of this circumstance in the description of our Website services. 

Data processing when visiting or using the Website

Visiting our Website without using any of our services - If you visit our Website without that you register yourself for our services or without otherwise providing any personal data yourself, we only process the Usage Date that are transmitted to us from your internet browser. We process these data to carry out, guarantee and improve the functionality of our Website. The legal bases are our Legitimate Interests. For additional information, see information on Use of cookies below. 


Contacting us – If you contact us by using our contact form or by sending us an email, we will store and process Name and Contact Data and any other information you provide us to answer your question. The legal bases are our Legitimate Interests. 


Opening and managing your Tomokachi Account – If you register a Tomokachi account on our Website, we will collect and store your Name and Contact Data and the Transaction Data that we require to perform our services with regards to the offering and sale of Tomokachi token (TMK) by way of an Initial Coin Offering to you. We will also use these data to provide customer care and support, to notify you of any changes to our services and to send you a verification email when you register the account. The legal basis is Contractual Necessity.  


Registering for our Newsletter - On our Website, you may subscribe to receive information about our services by our email newsletter. For the registration process we use the so-called double opt-in procedure. After you have given us your email address, we will send you a confirmation email to this email address. You will only receive the newsletter if you click on the confirmation link in this email. This ensures that only the actual owner of the email address can register for the newsletter. The legal basis is your Consent. You have the right to withdraw your Consent at any time with effect for the future. 




Tomokachi uses the bug analysis service provider Functional Software, Inc. dba Sentry, 132 Hawthorne Street, San Francisco, CA 94107 („Sentry“) to find bugs and analyze them. The transmission happens according to the requirements of Art. 46 DSGVO. Sentry stores and collects the data and presents the data for Tomokachi in a dashboard. Sentry stores the data in the USA and is committed to fulfill all of the requirements of EU-DSGVO (EU 2016/679) ( The user hereby agrees to the saving and storage of his or her data by Tomokachi and the transmission to Sentry. If the user does not want that Sentry saves and stores the user’s data, the user should not use the Tomokachi website. In order to delete the data saved by Tomokachi or Sentry, respectively, the user can send an e-mail to anytime (with subject “Deletion of Sentry data”; this has to be done independently from the possibility to delete the user’s profile). Otherwise, the data will be deleted after the period prescribed by law. Additional information can be found in Sentry’s Terms of Service ( and Privacy Policy ( Sentry saves and stores the following data: 

  • 6.1.1 Operating System Device 
  • 6.1.2 Operating System Version 
  • 6.1.3 Locale 
  • 6.1.4 Browser 
  • 6.1.5 Browser Version 
  • 6.1.6 IP-Address 
  • 6.1.7 Timestamp 
  • 6.1.8 Click and Movement Behavior (Buttons and Screens) 



When visiting the websites as well as all sub-pages) the following is important: When the user visits our websites, Tomokachi collects data only anonymized and solely for statistics and analyses purposes with the analytics service provider Mixpanel, 405 Howard Street, Floor 2, San Francisco, CA 94105, USA. The transmission happens according to the requirements of Art. 46 DSGVO. Mixpanel stores and collects the data and presents the data for Tomokachi in a dashboard. Mixpanel stores the data in the USA and is committed to fulfill all of the requirements of EU-DSGVO (EU 2016/679) via its DPA (Data Processing Addendum) ( The user hereby agrees to the saving and storage of his or her data by Tomokachi and the transmission to Mixpanel. If the user does not want that Mixpanel saves and stores the user’s data, the user should not visit the website. The data will be deleted after the period prescribed by law. Additional information can be found in Mixpanel’s Terms of Service ( and Privacy Policy ( When visiting the website, the following data is collected by Mixpanel: 

  • 6.2.1 Country, Region, City (Mixpanel uses the IP address to get country, region and city. Afterwards, however, the IP address is deleted or anonymized.) 
  • 6.2.2 Time zone 
  • 6.2.3 Browser 
  • 6.2.4 Browser Version 
  • 6.2.5 Device 
  • 6.2.6 Current URL 
  • 6.2.7 Initialer Referrer 
  • 6.2.8 Initiale Referring Domain 
  • 6.2.9 Operating System 
  • 6.2.10 Mixpanel Library 
  • 6.2.11 Referrer 
  • 6.2.12 Referring Domain 
  • 6.2.13 Screen Height 
  • 6.2.14 Screen Width 
  • 6.2.15 Search Engine 
  • 6.2.16 Search Keyword 
  • 6.2.17 UTM Parameters (ie. any UTM tags associated with the link a customer clicked to arrive at the domain) 
  • 6.2.18 Last Seen 

Mixpanel uses cookies on Tomokachi websites. Cookies are text files stored in a user’s browser to meet the obligations of Tomokachi, identify a user, offer more, better and more personalized features and more unique experiences (e.g. automatic re-login when visiting again), or help Tomokachi improve the Website continuously for the users. The data generated by the analysis is passed on to Mixpanel’s servers for processing and use. The user can exclude the use of cookies in the settings of his or her browser or delete existing cookies from his or her browser. If the user does not wish that his or her data is stored, he or she should not visit the Website. 

Use of cookies

We use cookies and similar tracking technologies to track the activity on our Website and to obtain certain information. 


Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze the services provided on our Website. 


The purpose of these cookies is to identify your computer during a later visit to our Website, when switching from one of our webpages to another of our webpages, and to be able to track the end of your visit. 


You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Website. 


Examples of Cookies we use are: 


  • Session Cookies. We use Session Cookies to operate our Website. Session Cookies are deleted after you leave our Website and close your browser. 
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings. 
  • Security Cookies. We use Security Cookies for security purposes. 

Asserting your rights

You have a number of rights concerning your personal information that we hold and use, including the following: 


  • Right of Access – You have the right to be informed about what personal information we hold about you and to a copy of this personal information. 
  • Right to Rectification – You have the right to have any inaccurate personal information which we hold about you updated or corrected. 
  • Right to Erasure – In certain circumstances you may request that we delete the personal information that we hold about you. 
  • Right to Complain – You have the right to lodge a complaint regarding the processing of your personal information to an applicable governmental or supervisory authority in the EU or EEA. 
  • Right to Object – Where we rely on our Legitimate Interests to process your data, you have the right to object to such use and we are required to discontinue such processing unless we can demonstrate an overriding legitimate interest in such processing. 
  • Right to Restriction – You have the right to request that we stop using your data in certain circumstances including if you believe that the data we hold about you is inaccurate or that our use of your data is unlawful. If you validly exercise this right, we will store your personal information and will not carry out any other processing until the issue is resolved. 


To assert these rights, please use the contact options listed under the point “General information about processing your data” above. 

Right to object and withdraw your consent to the processing of your data

If you have given your Consent to the processing of your data, you can withdraw your Consent at any time. If you withdraw your Consent, we are not allowed to process your data after the withdrawal. 

If the processing of your personal data is based on our legitimate interests, you may object to the processing. In the event of your objection, we request you to explain the reasons why we should not process your personal data as we have done. If your objection states reasons, we will examine the situation and will either stop or adjust the data processing, or will demonstrate our compelling legitimate reasons that allow us to continue the processing. 

Use of Google Analytics

Our Website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies. The information generated by the cookie about your use of this Website is usually transmitted to a Google server in the USA and stored there. However, if IP anonymization is activated on this Website, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area (EEA). Only in exceptional cases the full IP address will be sent to a Google server in the USA and truncated there. On behalf of us, Google will use this information to evaluate your use of the Website, to compile reports on website activity and to provide other services related to website usage and internet usage to us. 
The IP address transmitted by Google Analytics as part of Google Analytics will not be merged with other data provided by Google. 
You can prevent the storage of cookies by setting your browser software accordingly. However, please note that if you do so, you may not be able to use all the features of this Website. You may also prevent the collection by Google of the data generated by the cookie and related to your use of the Website (including your IP address) as well as the processing of this data by Google by using the browser plug-in that is available for download at 
This Website uses Google Analytics with the extension “_anonymizeIp ()”. As a result, IP addresses are processed in truncated form. This means that they do no refer to a person anymore. 
We use Google Analytics to analyze and improve the use of our Website. With the statistics we can improve our services and make them more interesting for you as a user. In the exceptional cases in which personal information is transferred to the US, Google participates in the EU-US Privacy Shield, The legal basis for the use of Google Analytics are our Legitimate Interests. 
Third-party information: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland. Terms of Use:, Privacy Policy:, and the Privacy Policy: 

Web links

Our Website also contains links to other internet services. If you are redirected to another website by clicking on one of the links, this Privacy Policy will no longer apply, but that of the respective website operator. 

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. 


We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the ‘effective date’ at the top of this Privacy Policy.


You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.