SwapzHub LLC (“Swapz”), a company registered in St. Vincent and the Grenadines (the “Company”), declares the following Privacy Policy, which includes a cookie policy (the “Policy”), in relation to its website https://swapz.app/ (the “Website” or the “Company’s Website”) and any website visitor (the “User”).
How the Company uses, shares, stores, and secures the information; and
How the User may access and control that information.
This Policy is associated with the terms and conditions document for the Company's Website, which can be viewed by any User.
User Information.
The Company has the capability to collect "Personal Information" from Users, which is defined as any combination of data, information, or both, that pertains to an identifiable individual and is either provided to the Company or gathered via the Company's Website. This Personal Information may be acquired through the User's voluntary disclosure or by their use of the Website.
It's worth noting that the Company refrains from collecting sensitive data or special category data about Users, such as information about their ethnic origin, political views, religion, trade union membership, genetic information, biometric details, health status, or sexual orientation.
Information Usage.
The Company will utilize any Personal Information in compliance with applicable laws and regulations, and specifically:
If a User has given consent for the use of their Personal Information for a specific purpose, they have the right to withdraw their consent at any time by contacting the Company. However, this will not affect any prior use of the Personal Information.
The Company does not share Personal Information with companies outside of its own group, if applicable, for marketing purposes unless there is express specific consent to do so.
For Website visitors or users located in the European Union, the legal bases for processing their information are outlined be in point 10.
Information Sharing.
The Company may share the Personal Information it collects with third-party service providers who help operate, support, and market its Website and other products and services. These providers may include website and application developers, data storage and backup providers, payment processors, business analysts, and providers of Anti-Money Laundering (''AML'') and Know Your Customer checks (''KYC'') and other relevant services.. The Company requires that these providers maintain the confidentiality and security of all Personal Information they process on the Company’s behalf, implement reasonable security measures, and comply with applicable laws and regulations.
The Company may share Personal Information in an anonymous or generalized form with third parties for research and analysis purposes to enhance its products and services. If a User employs third-party software in association with the Company's products or services, the software provider may have access to the User's Personal Information. The Company is not accountable for the policies and procedures of third-party software providers and suggests Users to review their privacy policies before using their software.
The Company cautions that the Website may provide links to third-party websites that are beyond its control. If a User decides to follow a link or submit information to a third-party website, their Personal Information will be governed by that third-party's policies. Furthermore, the Company may be required to share Personal Information with government and law enforcement officials in order to comply with applicable laws or regulations, even if they differ from those of the User or the Company.
Information Storage
All Personal Information provided by the User is stored on the Company’s servers or on a third-parties server to which only the Company has access to within the boundaries of relevant laws and regulations.
The Company only retains Personal Information for so long as it is reasonably necessary to fulfill the purposes they were collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
International Transfer of Information
It is common for companies to transfer and store Personal Information outside of the User's country of residence, especially for international companies. However, it is important to note that data protection laws may vary across different countries.
To ensure that the transfer of Personal Information is conducted in a secure and appropriate manner, the Company may use contractual clauses, corporate rules, and other appropriate mechanisms to safeguard the transfer of any Personal Information. These mechanisms are designed to ensure that the transfer of Personal Information complies with applicable data protection laws and regulations.
However, it is important to note that these mechanisms may not provide the same level of protection as the User's country of residence, and the User should be aware of the potential risks associated with the transfer of their Personal Information outside of their country of residence.
User’s rights
The User has the following right to:
request to receive some of the relevant Personal Information in a structured, commonly used, and machine-readable format, and request that it is transferred to another party; and withdraw consent at any time where the Company is relying on consent to process the relevant Personal Information (although this will not affect the lawfulness of any processing carried out before such consent withdrawal).
The Platform and the App enable Users to update certain information about themselves.
Policy Changes
The Company reserves the right to amend this Privacy Policy from time to time by posting the updated Privacy Policy on the Company's Website. By continuing to use the Company’s Website after the changes come into effect, the User agrees to be bound by the revised policy.
Children Privacy Policy
The Company's products and services are intended for individuals who are of legal age in their country of residence, and the Company does not knowingly collect any personal information from individuals who are not of legal age. If the Company becomes aware that it has collected personal information from someone who is not of legal age, it will take steps to delete that information.
European Union Users - GDPR
If a user is accessing the Company's website from the European Union (EU), different privacy laws may apply compared to other jurisdictions. The Company acknowledges this and has implemented measures to protect the personal information of users who may be transferring it to the Company for storage and processing in other countries.
Regarding the legal bases for collecting and using personal information of EU citizens or residents, it may depend on the specific context and the type of personal information being collected. The Company may rely on the following legal bases:
Performance of a contract: The use of personal information may be necessary to perform the terms and conditions or policies under which the Company operates its website. Consent: The Company may seek the user's consent for the use of technical information such as cookie data and geolocation data, and for the use of personal information for marketing purposes. The user may withdraw their consent at any time. Legitimate interests: The Company may use personal information for its legitimate interests, such as to improve its website, for security purposes, and fraud prevention, and to share information with affiliates for internal administration. The Company ensures that its interests do not override the user's data protection interests or fundamental rights and freedoms in such cases.
Rights under EU law:
If the User’s relevant Personal Information is subject to the protections offered by EU law, he/she may:
Access, correct, update or request deletion of any relevant Personal Information, at any time by contacting the Company using the contact details provided on the Website (in accordance with applicable data protection laws), provided that the Company may charge a reasonable fee for any manifestly unfounded, excessive or repetitive requests;
Object to the processing of any relevant Personal Information, ask the Company to restrict processing of any relevant Personal Information or request portability of any relevant Personal Information for the legitimate interests set out above. In certain circumstances, the Company may not be able to stop using the Personal Information, with motivated cause.
Withdraw consent at any time if the Company collected and processed any relevant Personal Information with consent;
Opt-out of any marketing communications that the Company (or any third party to whom the Company disclosed the Personal Information with consent) may send;
Complain to a data protection authority about the Company’s collection and use of any relevant Personal Information.
These rights apply only to Users who are subject to EU law.
The Company is the Data Controller in relation to its Website and is responsible for any relevant Personal Information, save for what pertains to other third-party service providers connected. The User may contact the Company through its Website if he/she has any concerns about this Policy and any relevant Personal Information.
Law and Jurisdiction
To the extent permitted by applicable law, this Policy and any disputes or claims arising out of or in connection with it or its subject matter or formation (including non-contractual disputes or claims) are governed by and construed in accordance with the laws of the St. Vincent and the Grenadines. You irrevocably agree that the courts of the St. Vincent and the Grenadines shall have exclusive jurisdiction to settle any dispute or claim that arises out of this Policy.