SWAPP Privacy Policy
1. General Information
1.1 This Privacy Policy outlines the rules for processing personal data by SWAPP (hereinafter referred to as the “Administrator”), the owner of the platform and mobile application enabling property exchange between users (hereinafter referred to as the “Users”).
1.2 The Administrator makes every effort to ensure that personal data is processed in accordance with applicable laws, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR).
2. Data Controller
2.1 The Data Controller is SWAPP, registered at [company address].
2.2 For matters related to personal data processing, you may contact the Administrator at: [email address].
3. Scope of Data Processed
3.1 The Administrator may process the following personal data of Users:
full name,
email address,
phone number,
home address (for the property being exchanged),
ID document photo (for identity verification),
transaction, exchange, and subscription data,
application usage information (IP address, cookies, device details).
3.2 This data is collected during:
account registration,
profile completion,
app usage,
contacting customer support,
making payments.
4. Purpose of Data Processing
4.1 Personal data is processed for the following purposes:
creating and managing user accounts,
verifying identity,
facilitating property exchanges,
processing payments and subscriptions,
communicating with Users,
handling complaints and inquiries,
analytical, statistical, and marketing purposes (with prior consent),
ensuring secure use of the platform.
5. Legal Basis for Processing
5.1 Data is processed on the basis of:
Article 6(1)(b) GDPR – performance of a contract (e.g. exchange transactions),
Article 6(1)(c) GDPR – legal obligations (e.g. invoicing),
Article 6(1)(f) GDPR – legitimate interest of the Administrator (e.g. fraud prevention),
Article 6(1)(a) GDPR – User’s consent (e.g. for marketing communications).
6. Data Sharing
6.1 The Administrator may share data with:
technology partners supporting the app’s operation,
payment processors,
hosting and data storage providers,
legal and accounting service providers,
authorized public authorities – only as required by law.
6.2 Data is not transferred outside the European Economic Area unless adequate data protection safeguards are in place.
7. Data Retention Period
7.1 Data will be retained:
as long as necessary to provide services and facilitate exchanges,
for the duration of the user’s account,
for the period required by law (e.g. tax regulations),
until consent is withdrawn – where data is processed based on consent.
8. User Rights
8.1 Users have the right to:
access their data,
rectify inaccurate data,
request data deletion (“right to be forgotten”),
restrict data processing,
transfer their data,
object to processing,
withdraw consent at any time,
lodge a complaint with a data protection authority.
8.2 To exercise these rights, please contact the Administrator.
9. Cookies and Tracking Technologies
9.1 The app uses cookies for:
ensuring correct operation,
remembering user preferences,
collecting statistics,
marketing purposes.
9.2 Users may manage cookies in their browser or app settings.
10. Data Security
10.1 The Administrator applies appropriate technical and organizational measures to protect personal data from:
unauthorized access,
loss,
accidental disclosure or destruction.
10.2 Data access is restricted to authorized and trained personnel.
11. Changes to the Privacy Policy
11.1 The Administrator reserves the right to modify this Privacy Policy. The updated version will be published in the app and on the website.
11.2 Continued use of the platform after changes implies acceptance of the new terms.
Thank you for your trust.
Your privacy matters to us.