Privacy Policy

Effective Date: May 14, 2025

1. Executive Summary

At Swapo, we recognize that your personal information is among your most valuable assets. This Privacy Policy provides a comprehensive overview of the types of data we collect, the purposes for which it is used, the legal grounds for processing, and the measures we take to safeguard your privacy. We never sell your personal information. You have robust control over your data, including rights to access, correct, delete, and restrict processing. Should you have any questions or wish to exercise your rights, please contact us at swapoorg360@gmail.com.

2. Introduction

This Privacy Policy governs the collection, use, disclosure, and protection of personal information by Swapo Inc. (“Swapo,” “we,” “our,” or “us”) in connection with our online marketplace and related services (collectively, the “Services”). By accessing or using the Services, you acknowledge that you have read, understood, and agree to this Policy. If you do not agree, please do not use the Services.

3. Collected Data

Registration details, platform usage records, financial transactions, and communications.

4. Why We Process

To deliver our services, maintain security, personalize your experience, and comply with legal requirements.

5. Data Sharing

Only with trusted third-party processors, as required by law, or during business reorganization. We do not sell your personal information.

6. Your Control

You may access, rectify, erase, restrict or object to processing, obtain data portability, and withdraw consent.

1. Introduction

2. Account Registration and Profile

When you create an account, we collect your full name, email address, phone number, username, password (securely hashed), profile photograph, biographical details, and any verification documents you provide, such as government-issued identification. This information is necessary to authenticate your identity, facilitate communications, and comply with legal verification requirements.

3. Usage and Technical Data

We automatically gather information about your interactions with the Services, including but not limited to: pages viewed, buttons clicked, timestamps of your activity, the IP address from which you access the Services, browser type and version, device type and operating system, and geolocation data (at a city-level approximation). This data enables us to analyze trends, monitor system performance, and improve user experience.

4. Transactional and Financial Data

In processing token purchases, session bookings, or other financial transactions, we collect payment method information (handled by secure third-party processors), billing address, purchase amount, refund or dispute details, and transaction timestamps. We do not retain full payment card data on our systems.

5. Communications Data

All messages exchanged between users via our platform, support inquiries you submit, survey responses, and feedback are stored to facilitate service delivery scope, resolve disputes, and enhance customer support.

1. Introduction

Under applicable data protection laws, we rely on the following legal grounds:

2. Consent

Where you have provided explicit consent for specific processing activities (e.g., marketing communications).

3. Contractual Necessity

To perform our obligations under your user agreement, including processing transactions and delivering Services you request.

4. Legal Obligation

To comply with applicable laws, regulations, and court orders (e.g., record retention for financial transactions).

5. Legitimate Interests

To operate, secure, improve, and personalize our Services, provided such interests do not override your fundamental rights and freedoms.

1. Introduction

2. We use your personal information for the following purposes

To create and manage your account, authenticate your identity, and process passwords and security.
To facilitate the purchase of tokens, booking of sessions, and other financial transactions.
To enable communication between you and other users, as well as with our customer support team.
To personalize your experience by providing content and recommendations tailored to your interests and activity.
To conduct analytics and gather insights that help us improve the quality, functionality, and security of our Services.
To detect, prevent, and address technical issues, fraud, abuse, and other harmful or illegal activity.
To send you important notices regarding your account, updates to the Services, and, where you have consented, marketing materials.

1. Introduction

We retain personal information only as long as necessary to fulfill the purposes for which it was collected, including to comply with legal, accounting, or reporting obligations. Typical retention periods include

2. Account Information

Retained until you delete your account, plus an additional three (3) years for audit and compliance purposes.

3. Transactional Records

Retained for a period of seven (7) years to satisfy tax and regulatory requirements.

4. Communications and Support Data

Retained for two (2) years to enable ongoing support and dispute resolution.

1. Introduction

2. Children’s Privacy

Our Services are designed for users who are at least sixteen (16) years of age. We do not knowingly collect or solicit personal information from individuals under the age of sixteen. If we learn that we have inadvertently collected data from a child under sixteen, we will promptly delete that information. If you believe we might have any information from or about a child under sixteen, please contact us at swapoorg360@gmail.com.

1. Introduction

2. International Data Transfers

Your information may be transferred to, stored at, or processed by servers located outside your jurisdiction, including countries whose data protection laws may be different. Whenever we transfer your personal data internationally, we implement appropriate safeguards such as Standard Contractual Clauses approved by relevant authorities or other lawful transfer mechanisms to protect your privacy rights.

1. Introduction

We employ a combination of administrative, technical, and physical safeguards to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include

Encryption of data in transit using industry-standard protocols (e.g., TLS).
Access controls and authentication mechanisms to restrict data access to authorized personnel only.
Regular security assessments, vulnerability scans, and penetration tests.
Secure development practices and patch management.
Incident response procedures to promptly address any suspected data breaches.

1. Introduction

Depending on your jurisdiction, you may have the following rights regarding your personal information

2. Access

Request a copy of the personal data we hold about you.

3. Rectification

Request correction of inaccurate or incomplete data.

4. Erasure

Request deletion of your personal data, subject to legal obligations.

5. Restriction

Request limitation of processing under certain conditions.

6. Objection

Object to processing based on legitimate interests or direct marketing.

7. Portability

Request a machine-readable copy of data you provided to us.

8. Withdraw Consent

Withdraw any consent you have previously given for specific uses.

To exercise these rights, please submit a request to swapoorg360@gmail.com. We will verify your identity before responding and will comply within any legally required timeframe.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer at:

Email: swapoorg360@gmail.com

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make significant changes, we will notify you via email (if you have provided one) and update the “Effective Date” at the top of this page. Continued use of the Services following such updates constitutes acceptance of the revised Policy.

Privacy Policy

1. Executive Summary

2. Introduction

3. Collected Data

4. Why We Process

5. Data Sharing

6. Your Control

1. Introduction

2. Account Registration and Profile

3. Usage and Technical Data

4. Transactional and Financial Data

5. Communications Data

1. Introduction

2. Consent

3. Contractual Necessity

4. Legal Obligation

5. Legitimate Interests

1. Introduction

2. We use your personal information for the following purposes

1. Introduction

2. Account Information

3. Transactional Records

4. Communications and Support Data

1. Introduction

2. Children’s Privacy

1. Introduction

2. International Data Transfers

1. Introduction

1. Introduction

2. Access

3. Rectification

4. Erasure

5. Restriction

6. Objection

7. Portability

8. Withdraw Consent

Subscribe

About

Support

swapoorg360@gmail.com

Privacy Policy

1. Executive Summary

2. Introduction

3. Collected Data

4. Why We Process

5. Data Sharing

6. Your Control

1. Introduction

2. Account Registration and Profile

3. Usage and Technical Data

4. Transactional and Financial Data

5. Communications Data

1. Introduction

2. Consent

3. Contractual Necessity

4. Legal Obligation

5. Legitimate Interests

1. Introduction

2. We use your personal information for the following purposes

1. Introduction

2. Service Providers

3. Legal and Regulatory Authorities

4. Business Transactions

5. Public Profile Information

1. Introduction

2. Account Information

3. Transactional Records

4. Communications and Support Data

1. Introduction

2. Children’s Privacy

1. Introduction

2. International Data Transfers

1. Introduction

1. Introduction

2. Access

3. Rectification

4. Erasure

5. Restriction

6. Objection

7. Portability

8. Withdraw Consent

Subscribe

About

Support

swapoorg360@gmail.com