Privacy policy

Swirl K.K. ("we," "us," or "our") sets forth this Privacy Policy ("Policy") regarding the handling of your personal information in connection with our online store, swirlwine.co.jp (the "Site"). This Policy is designed to comply with Japan's Act on the Protection of Personal Information ("APPI") and other applicable laws and to ensure the appropriate handling of your personal information.

1. Business Operator Information

  • Business name: Swirl K.K.
  • Address: Kuwano Building 2F, 6-23-4 Jingumae, Shibuya-ku, Tokyo 150-0001, Japan
  • Representative: Federico Fanelli
  • Personal information inquiries: hello@swirlwine.co.jp

2. Personal Information We Collect

In connection with your use of the Site and your purchases, we collect:

  • Order information: name, billing address, shipping address, phone number, email address, payment information (including credit card numbers), date of birth / age, and wine preferences.
  • Customer support information: the above plus the content of your inquiry.
  • Device and usage information: IP address, browser type and version, time zone, cookie information, products and pages viewed, search terms, and your interactions with the Site (collected automatically via cookies, log files, web beacons, tags, and pixels).

3. Purposes of Use

We use personal information to:

  • Perform our contract with you, including selling and shipping products, processing payments, and providing invoices and order confirmations;
  • Verify age and prevent the sale of alcohol to persons under the age of 20;
  • Provide customer support and respond to inquiries;
  • Detect and prevent fraudulent orders and misuse;
  • Maintain, analyze, and improve the Site;
  • With your consent or in line with your preferences, send you information about new products, services, and promotions (e.g., newsletters).

We retain personal information for as long as necessary to achieve the purposes above or as required by law, after which we appropriately delete or anonymize it.

4. Provision to Third Parties

We will not provide personal information to third parties without your prior consent, except where: required by law; necessary to protect a person's life, body, or property where consent is difficult to obtain; we receive a lawful request from a court, investigative authority, or other public body; or it is necessary to protect our rights, property, or services.

5. Outsourcing (Entrusted Handling of Personal Data)

To the extent necessary to achieve the purposes above, we may entrust the handling of personal data to service providers, whom we appropriately supervise, including:

  • E-commerce platform: Shopify Inc. (Shopify Privacy Policy: https://www.shopify.com/legal/privacy)
  • Shipping carriers
  • Warehouse and logistics providers
  • Payment processors
  • Analytics: Google Analytics (Google Privacy Policy: https://policies.google.com/privacy / opt-out: https://tools.google.com/dlpage/gaoptout)

6. Transfers to Third Parties Located Overseas

Through services such as Shopify, your personal information may be initially processed in Ireland and then transferred to and stored or further processed in countries outside Japan, including Canada and the United States. For information on the data protection systems in those countries and the measures Shopify takes, see https://help.shopify.com/manual/your-account/privacy/GDPR.

7. Security Measures

We take necessary and appropriate measures to prevent the leakage, loss, or damage of personal data, including:

  • Restricting and managing access rights to personal data;
  • Protecting data in transit through encryption (SSL/TLS);
  • Selecting and supervising service providers;
  • Maintaining internal rules on the handling of personal information and informing our staff (organizational and personnel measures);
  • Managing the devices and media that handle personal data to prevent unauthorized access and theft (physical measures).

You may direct questions about our security measures to the contact below.

8. Disclosure, Correction, and Suspension of Use of Retained Personal Data

You may request notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, erasure, and suspension of third-party provision of your retained personal data, as well as disclosure of third-party provision records. Please contact the inquiry window below; we will respond in accordance with law after verifying your identity.

9. Cookies and Behavioural Advertising

The Site uses cookies and similar technologies to provide functionality, analyze usage, and optimize advertising. Most browsers accept cookies automatically, but you can refuse or manage cookies through your browser settings; disabling cookies may make some features of the Site unavailable. We may work with advertising partners such as Google to show you interest-based ads; to opt out, use each provider's settings (e.g., Google: https://www.google.com/settings/ads/anonymous) or the Digital Advertising Alliance (http://optout.aboutads.info/). Because there is no consistent industry standard for "Do Not Track" signals, we do not alter our data practices in response to them.

10. Minors

The Site sells alcohol and is not available to persons under the age of 20. We do not intentionally collect personal information from persons under 20. If you are a parent or guardian and believe your child has provided us with personal information, please contact the inquiry window below and we will delete it.

11. Customers Resident in the EU/EEA (GDPR)

For customers resident in the EU/EEA, we process personal information under the GDPR on the legal bases of your consent, performance of a contract, compliance with legal obligations, and our legitimate interests, among others. You have the right to access, correct, erase, and port your personal information. To exercise these rights, or if you are not satisfied with our response, please contact the inquiry window below or lodge a complaint with your local data protection authority.

12. Changes to this Policy

We may update this Policy from time to time for operational, legal, or regulatory reasons. Changes take effect when posted on this page.

13. Contact and Complaints

For inquiries or complaints regarding this Policy or our handling of personal information:

  • Swirl K.K., Personal Information Inquiry Window
  • Email: hello@swirlwine.co.jp
  • Address: Kuwano Building 2F, 6-23-4 Jingumae, Shibuya-ku, Tokyo 150-0001, Japan

Established: 18 August 2021 Last updated: 10 June 2026