TIME COIN S.A. — PRIVACY POLICY

I. INTRODUCTION

This Privacy Policy (“Policy”) explains how TIME COIN S.A. (“Company,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal data in connection with the sale of Packages, the Referral Compensation Program, and any related web interface or dashboard (the “Platform”).

By using the Platform, purchasing a Package, or participating in the Referral Compensation Program, you acknowledge that you have read and understood this Policy.

II. DATA CONTROLLER

The data controller responsible for personal data processed in connection with the Platform is:

TIME COIN S.A., a company incorporated under the laws of the Republic of Panama, registered in the Public Registry of Panama under Folio 155771560, with registered office at Calle 50, Plaza 2000, Piso 17, Ciudad de Panamá, Provincia de Panamá, República de Panamá.

Data protection inquiries: [email protected].

The Company processes personal data in accordance with the Republic of Panama’s Law No. 81 of 2019 on the Protection of Personal Data and its implementing Executive Decree No. 285 of 2021 (together, the “Panama Data Protection Law”), enforced by the National Authority for Transparency and Access to Information (Autoridad Nacional de Transparencia y Acceso a la Información, “ANTAI”). Where a data subject is located in a jurisdiction whose law imposes additional or different requirements (for example, the EU/UK GDPR), the Company will apply the standard that provides the data subject with the greater protection to the extent required by applicable law.

III. INFORMATION WE COLLECT

Data you provide directly may include:

• identification data (full name, date of birth, nationality, government-issued ID) collected for KYC/AML verification as described in the KYC/AML Policy;
• contact data (email address, phone number, mailing address);
• connected blockchain wallet address;
• payment and transaction data, including Package purchase records, blockchain transaction hashes, and payout records under the Referral Compensation Program;
• referral relationships (who introduced you, and whom you have introduced) to the extent necessary to calculate compensation;
• records of correspondence with support or compliance staff.

Data collected automatically may include IP address, device and browser metadata, and usage logs collected through cookies as described in the Cookies Policy.

IV. PURPOSES AND LEGAL BASES OF PROCESSING

The Company processes personal data for the following purposes and legal bases:

1. Performance of a contract — to process your Package purchase, operate your Platform account, and calculate and pay Referral Compensation Program compensation.
2. Compliance with a legal obligation — to perform KYC/AML verification and sanctions screening under Panama’s Law No. 23 of 2015 on the Prevention of Money Laundering and the guidance of the Unidad de Análisis Financiero (UAF), and to comply with tax and reporting obligations.
3. Legitimate interests — to maintain platform security, detect and prevent fraud (including misuse of the Referral Compensation Program), and improve the Platform, provided this does not override your rights.
4. Consent — for optional communications such as marketing updates, which you may withdraw at any time.

V. DATA SHARING AND DISCLOSURE

The Company may share personal data with:

• service providers performing hosting, identity verification, analytics, or payment functions on the Company’s behalf, under written confidentiality and data-processing terms;
• the resident agent, auditors, and professional advisers of TIME COIN S.A. as necessary for corporate compliance;
• competent authorities, including ANTAI and the UAF, where disclosure is required by applicable law or a valid legal process;
• a successor entity in the event of a merger, acquisition, or corporate restructuring, subject to equivalent safeguards.

The Company does not sell personal data to third parties for advertising purposes.

VI. INTERNATIONAL DATA TRANSFERS

Because the Company is domiciled in Panama and Participants access the Platform from multiple jurisdictions, personal data may be processed in Panama and in the jurisdictions where the Company’s service providers operate. Where the Panama Data Protection Law requires an adequacy assessment or contractual safeguards for a cross-border transfer, the Company will apply such measures, including standard contractual clauses where appropriate.

VII. DATA RETENTION

Account and transaction data are retained for the duration of your relationship with the Company and for a further period thereafter as required to satisfy accounting, tax, and legal obligations. KYC/AML records are retained for a minimum of five (5) years following the end of the business relationship, consistent with international AML standards referenced by Panama’s AML/CFT framework.

VIII. DATA BREACH NOTIFICATION

In the event of a security incident affecting personal data, the Company will notify ANTAI and, where the incident is likely to result in a high risk to your rights, notify you directly, within the timeframe required by the Panama Data Protection Law (currently seventy-two (72) hours of becoming aware of the incident under Executive Decree No. 285 of 2021), including a description of the incident and the measures available to you to protect your interests.

IX. YOUR RIGHTS

Subject to the Panama Data Protection Law, you have the right to: access the personal data the Company holds about you; request rectification of inaccurate data; request erasure where legally permitted; request restriction of processing; object to processing based on legitimate interests; request data portability; and withdraw consent for processing based on consent, without affecting the lawfulness of prior processing.

Requests should be sent to [email protected]. The Company will respond within the period required by applicable law (currently ten (10) business days for access requests under Panamanian law). You also have the right to lodge a complaint with ANTAI.

X. SECURITY MEASURES

The Company applies administrative, technical, and organizational measures appropriate to the risk, including encryption, access controls, and regular security review. No system is completely secure; the Company cannot guarantee absolute security of data transmitted over the internet or stored on third-party infrastructure.

XI. CHILDREN’S PRIVACY

The Platform is not directed at, and is not intended for use by, individuals under eighteen (18) years of age. The Company does not knowingly collect personal data from minors; if the Company becomes aware that it has done so, it will delete such data promptly.

XII. UPDATES TO THIS POLICY

The Company may revise this Policy from time to time. The updated Policy will be published on the Platform with a revised effective date. Continued use of the Platform after publication constitutes acceptance of the revised Policy.

XIII. CONTACT INFORMATION

For privacy matters, please contact TIME COIN S.A. at [email protected] or by post at Calle 50, Plaza 2000, Piso 17, Ciudad de Panamá, Provincia de Panamá, República de Panamá.