PRIVACY POLICY
1. INTRODUCTION
1.1. This Privacy Policy for Personal Data, together with the Rules for the Use of the SWAPPA System (as well as any other documents mentioned in this Policy), describes how SWAPPA collects, processes, uses and discloses your Personal Data, including data that we receive from you or that you provide in the process of using the website www.swappa.ws, as well as its services, programs and products.
1.2. SWAPPA refers to an ecosystem that includes SWAPPA websites (whose domain names include, but are not limited to www.swappa.ws), mobile applications, clients and other applications that are designed to provide SWAPPA services and include independently managed platforms.
This Privacy Policy applies to all SWAPPA platforms, websites and divisions of SWAPPA operators.
2. YOUR CONSENT
2.1. The use of Site services means the unconditional consent of the User with this Policy and the conditions for processing his personal information specified in it; in case of disagreement with these conditions, the User should refrain from using the services.
3. LEGAL GROUNDS FOR THE USE OF YOUR PERSONAL DATA
Personal data processing has the following legal grounds: – Contractual obligations
We will use your Personal Data for the following purposes: – to fulfill our obligations under the contract concluded with you. – to verify and confirm your identity for the purpose of creating your account and carrying out administrative functions on it. – to process transactions passing through your SWAPPA account and (or) card, as well as to fulfill your instructions on your account.
3.1. We will provide you with important information about available products and services, as well as provide necessary technical support and maintenance. – Legal obligation
3.2. We will use your Personal Data to fulfill the legal obligations imposed on us, to verify and confirm your identity in the process of passing KYC ("identification, verification and customer due diligence") procedures, as well as to provide the necessary assistance to authorities in conducting investigations in accordance with the requirements of applicable law. We may collect and store your Personal Data for risk management purposes, as well as to identify and prevent fraudulent and other illegal or prohibited actions. – Legitimate interests
3.3. We may use your Personal Data to monitor, analyze and improve our Services, website operations and functionality, as well as to notify of changes in our policy and terms of use. – Consent
3.4. With your unconditional consent, we may use your Personal Data to contact you by email to provide you with information about our products and services or for other business purposes. You may withdraw such consent at any time, and we will cease processing this information.
4. INFORMATION ABOUT THE PERSONAL DATA OPERATOR AND THE PERSONAL DATA PROTECTION PROCESSOR
4.1. "Personal Data Operator" is a company that determines the purposes and means of Personal Data processing. The Operator of Personal Data processed by us, collected in connection with the provision of SWAPPA services, is Swap Digital Group LLC. You can contact our Personal Data Protection Operator by email: info@swappa.ws
4.2. In connection with the provision of the SWAPPA services, the collection and processing of Personal Data are outsourced to an independent third-party service provider (Processor) integrated through an API. Such Processor shall process Personal Data only to the extent required for the business purposes set forth herein, and exclusively on the documented instructions of the Operator. The full list of engaged API service providers is available upon formal request.
5. WHAT IS "PERSONAL DATA"?
5.1. Personal data means "any information about a specific or identifiable natural person ("data subject")". In other words, Personal Data is any information about you that allows you to be identified. The Personal Data we collect and use is listed in this Policy.
6. WHAT PERSONAL DATA DOES SWAPPA COLLECT AND PROCESS?
Information you provide: – by filling out any forms, including when registering to access our services, subscribing to our newsletter or when sending us messages about problems; – by interacting with us in any way; – by requesting information about our products and services;
What personal information does SWAPPA collect and process: – first name, last name, patronymic, address and date of birth; – email address and device information; – username, password and other registration information; – details of your bank account, including account number, bank branch number, SWIFT code and international bank account number (IBAN); – details of your SWAPPA account, the debit card linked to it, as well as any other debit and credit cards you register in our System, including the expiration dates of such cards and CVC codes (three last digits of the number on the back of the card); – data and information obtained during a comprehensive check, including documents proving identity, copies of any other documents you provide for the purpose of establishing your identity, as well as any other information necessary to provide our services, your image in photo or video format;
6.1. financial information in appropriate cases. – Information received from third parties. We may also receive your Personal Data through third parties, including, in particular, the following information: – information received by a company that is part of the SWAPPA Group of companies; – information received from payment systems (such as Visa, Mastercard, etc.), anti-fraud organizations, credit bureaus, executive bodies and law enforcement; – information received from public sources, such as company registers, websites intended for in-depth counterparty verification;
6.2. information from social networks. – Information about financial transactions
6.3. Information about receipts and payments to your account, including information about the date, amount, currency, participants in the payment transaction, information about text messages sent and received with payments, payment methods used, technical usage data, as well as geolocation data. – Information from your device.
When using our website, we can collect the following technical information:
6.4. the name of your Internet service provider (IP address), network environment data, credentials, information about browser type and its settings, information about time zone, device used, unique device identifier, information about mobile network, mobile operating system and mobile browser type, as well as information about date, time and session duration.
7. AUTOMATED DECISION MAKING
7.1. Decisions regarding risk assessment and fraud prevention, including user profile verification, are not based on manual analysis and are performed using automated tools, including through API integrations with engaged third-party services. However, such automated tools are not used to make decisions that produce legal effects concerning the User or otherwise significantly affect his or her rights and legitimate interests within the scope of providing the SWAPPA services.
8. COOKIES
8.1. When using the Services, we may use data files (cookies), which are stored on your device. Cookies are used to identify you as a Platform user, collect data about your use of the Services, personalize them to your needs, and collect information about your device.
9. DATA SECURITY
9.1. Ensuring the protection of your personal information is our top priority.
9.2. We strive to take various measures to ensure the necessary security of your personal information in the process of your application submission or input, transmission of your personal information or access to it. We use data encryption methods and authentication procedures to prevent unauthorized access to our system and your data.
9.3. All confidential information provided is transmitted using the Secure Socket Layer (SSL) protocol.
9.4. Access rights to your data are provided only to those of our employees who need such access to perform their job duties. Our employees regularly undergo training that tells them about the importance of maintaining the confidentiality and secrecy of Personal Data. We regularly improve our security mechanisms to ensure compliance with the strictest requirements of advanced industry standards, thereby ensuring a high level of protection of your Personal Data.
9.5. In turn, the Data Processor (PROCESSOR) continuously adhere to and implement appropriate technical and organizational measures against unauthorized or illegal processing, access, disclosure, copying, modification, storage, reproduction, display or dissemination of Personal Data, as well as against accidental or illegal loss, destruction,
9.6. Modification, disclosure or damage to Personal Data.
On your part, we expect you to comply with a number of simple rules: – Always use a strong password and do not use the same password for multiple accounts; – Never share your password with anyone. Our representatives will never ask for user passwords, so you should be careful about any such requests and report them to us by contacting support.
10. DATA STORAGE
10.1. Your Personal Data will be stored for as long as is necessary to fulfill the specific purposes for which it was collected, except in cases where the law provides for mandatory storage of personal information for a period specified by law. Once your personal information is no longer of interest to us, we will delete it without the possibility of recovery.
11. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES
When providing our services, we may need to transfer your Personal Data to third parties, in particular:
12. CROSS-BORDER DATA TRANSFER
12.1. Different countries use different legislation for Personal Data protection. Given the international nature of our business, we may need to transfer your Personal Data to countries outside the territory of the Republic of Azerbaijan and your country of residence. Regardless of where your Personal Data is processed, we will make every effort to ensure that any transfer of your Personal Data is subject to appropriate contractual provisions established to ensure the protection of your privacy rights, and will give you protection in the unlikely event of misuse of your Personal Data. SWAPPA provides technical, organizational and contractual guarantees (including standard contractual terms) to guarantee the transfer of Personal Data in accordance with applicable data protection rules. We strive to properly protect your Personal Data when it is transferred to recipients outside your country of residence and take all reasonably necessary measures to ensure the safe handling of your data in accordance with this Privacy Policy.
13. LINKS TO THIRD-PARTY WEBSITES
13.1. Our website may contain links to third-party products or services. We do not control and are not responsible for third-party websites that the User may visit through links available on our Site. We welcome your comments and suggestions about such third-party websites. Please be vigilant and familiarize yourself with their privacy policy before providing such websites with your Personal Data.
14. RIGHTS OF THE DATA SUBJECT
14.1. In accordance with this Privacy Policy, you have the right to control how your Personal Data is processed. You have the following rights:
14.2. Right to information. You have the right to receive information about the processing (collection and use) of your Personal Data.
14.3. Right of access. You have the right to request confirmation as to whether we are processing your Personal Data. You may also request information on how we collect, transmit and use your personal information.
14.4. Right to clarification. You have the right to verify your Personal Data and make corrections to outdated or inaccurate Personal Data.
14.5. Right to data deletion ("right to be forgotten"). You have the right to require us to delete your Personal Data if there is no objective need to process such Personal Data for legitimate business purposes provided for in this Policy or applicable law.
14.6. Right to restrict processing and right to object. You have the right to require us to restrict the processing of your Personal Data, to object to the processing of your Personal Data, as well as to object to the use of automated decision-making methods.
14.7. Right to data portability. If technically feasible, we will, at your request, provide you with your Personal Data or transfer it to another Personal Data controller in a structured, widely used and machine-readable format.
14.8. Right to withdraw consent. You have the right to withdraw your consent to the processing of your Personal Data at any time by changing the settings in your account or by sending an appropriate email to info@swappa.ws, specifying which specific consent you are withdrawing.
14.9. Right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with the supervisory authority at your location regarding the Controller's processing of Personal Data. The procedure for lodging a complaint is described in detail in Section 13 of this Policy.
14.10. Reasonable access to your Personal Data will be provided within one month of receiving your request. If access cannot be provided within the above period, we will inform you of the exact date when the information will be provided.
14.11. You can contact us with any questions regarding the exercise of your rights and send them to info@swappa.ws. Before disclosing any personal information to you, we may ask you to provide a document proving your identity.
14.12. We may charge a fee for providing access to Personal Data to cover our own costs associated with providing you with information about the Personal Data we have that relates to you.
14.13. Please note that we will attempt to fulfill any requests you make regarding the exercise of your rights, but in some cases there may be legal or other grounds why we cannot or are not obliged to fulfill such a request. In this case, we will be forced to reject your request or fulfill it only partially.
15. CHANGES TO OUR PRIVACY POLICY
15.1. All changes that we may make to our Privacy Policy in the future will be published on this page and, if necessary, brought to your attention in the news on the service page. When an updated version of the SWAPPA Privacy Policy is released, you automatically accept the updated terms and agree to comply with the updated Privacy Policy. If you disagree with the changed content, you should immediately stop accessing SWAPPA.
16. CONTACT PERSON
16.1. If you have any questions, comments, requests, or if you wish to leave comments regarding our Privacy Policy, please send them to our Personal Data Protection Officer at the following email address: info@swappa.ws.
17. CAN CHILDREN USE SWAPPA SYSTEM SERVICES?
17.1. SWAPPA does not allow persons under the age of 18 to use the services and services of the SWAPPA system.
18. DOES SWAPPA TRANSFER MY PERSONAL INFORMATION?
18.1. Information about our users is very important to our business, and we do not engage in the sale of personal information of our users to other persons.
18.2. SWAPPA transfers users' personal information only in the manner and for the purposes described in this Privacy Policy, and to subsidiaries or affiliated companies of SWAPPA that either fall under this Privacy Policy or follow methods at least as protective as those described in this Privacy Policy.
18.3. Moreover, third-party service providers we hire to perform functions on our behalf, such as data analysis, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risk, have access only to the personal information necessary to perform their functions and may not use it for other purposes. Additionally, they must process personal information in accordance with our contractual agreements and only in accordance with applicable data protection laws.
18.4. Business transfer: As we continue to develop our business, we may sell or purchase other businesses or services. In such transactions, user information is usually one of the transferred business assets, but remains subject to the promises made in any prior privacy policy (unless the user consents otherwise). Additionally, in the unlikely event that SWAPPA is acquired or practically all of its assets are acquired, user information would be one of the transferred assets.
19. HOW PROTECTED IS MY INFORMATION?
19.1. We design our systems with your security and privacy in mind. We work to protect the security of your personal information during transmission using encryption protocols and software.
19.2. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. Our security procedures mean that we may ask you to confirm your identity to protect you from unauthorized access to your account password. We recommend that you use a unique password for your SWAPPA account that is not used for other online accounts, and log out when you are done using a shared computer.
20. WHAT INFORMATION CAN I ACCESS?
20.1. You can access your information, including your name, address, payment methods, profile information and transaction history, in the "Your Account" section on the website.
21. RESPONSIBILITY
21.1. In the process of using and complying with this Privacy Policy with respect to each of the subjects, responsibility is provided for, which is established by the applicable legislation of the Republic of Azerbaijan.