This Privacy Policy explains how information about you is collected, used by SWAG when you use our websites, mobile applications and other online products and services (collectively, the "Services") or when you otherwise interact with us. We may change this Privacy Policy from time to time, therefore we encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy.

Applicability and GDPR Compliance

This Privacy Policy applies worldwide. However, if you are located in the European Union (EU) or European Economic Area (EEA), your personal data is processed in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679. SWAG (OPERIFY Ltd. and its affiliates) acts as the data controller for your personal data. Our processing activities comply with GDPR principles, including lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality, and accountability. If you have questions about GDPR compliance, contact us at support@swag.live.

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you create an account, use the Services to send or receive messages, including photos or videos taken via our Services ("SWAG”), request customer support or otherwise communicate with us. The types of information we may collect include your username, password, email address, phone number, age, gender and any other information you choose to provide.

We kindly suggest you to provide contents (such as messages, photos, videos, captions) which you own the copyright. We cannot prevent others from making copies of your contents (e.g., by taking a screenshot). You should not use SWAG to send messages if you want to be certain that the recipient cannot keep a copy.

Information we receive from others

In addition to the information you provide us directly, we receive information about you from others, including:

Other Users
Social Media
Other Partners

HOW WE USE INFORMATION

The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

To administer your account and provide our services to you

Create and manage your account
Provide you with customer support and respond to your requests
Complete your transactions
Communicate with you about our services, including order management and billing

To ensure a consistent experience across your devices

Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.

To provide new SWAG services to you

Register you and display your profile on new SWAG features and app
Administer your account on these new features and app

To improve our services and develop new ones

Administer focus groups and surveys
Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)
Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

To prevent, detect and fight fraud or other illegal or unauthorized activities

Address ongoing or alleged misbehavior on and off-platform
Perform data analysis to better understand and design countermeasures against these activities
Retain data related to fraudulent activities to prevent against recurrences

To ensure legal compliance

Comply with legal requirements
Assist law enforcement
Enforce or exercise our rights, for example our Terms

INFORMATION SHARING

We take your information security very seriously and are committed to protecting your personal data. We will never sell, rent, or trade your personal data to any third party.

In order to provide you with a better and more personalized service experience, we may share your personal data with our trusted partners, such as:

Data analytics companies that help us with data analysis and marketing campaigns.
Customer service platform providers that help us provide customer service.

We strictly require these partners to take appropriate confidentiality measures to protect the security of your personal data.

In addition, we may disclose your personal data in the following circumstances:

To comply with applicable laws, regulations, legal processes, or government requests.
To detect, prevent, or address fraud, security, or technical issues.

Except for the above circumstances, if there is any other need to disclose your personal data, we will notify you before disclosure and will only proceed with your consent.

HOW WE PROTECT YOUR INFORMATION

We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately.

CHILDREN’S PRIVACY

Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.

Others

Account Information

You may update information about yourself by editing your account settings within our app. If you have any problem, please contact us at [support@swag.live](mailto:support@swag.live).

Push Notifications/Alerts

We provides services for information notification (including but not limited to sending event information from time to time via push, SMS or email). If you do not wish to receive any event information, please feel free to contact our customer service, our customer service will assist you to cancel the event information notification settings.

Cookie Notice

This Cookie Notice applies to your use of https://swag.live and any other websites, applications, or services provided by OPERIFY Ltd. (with its affiliates, “SWAG”, “we” or “us”) that link to this Cookie Notice (collectively, the “swag.live - Terms of Service”). We use certain technologies to collect information through the SWAG Services. In this Cookie Notice, we refer to these technologies, which include HTTP cookies, local storage, pixel tags and web beacons, collectively as “cookies.” This notice explains the different types of cookies used on SWAG Services and how you can control them. We may change this Cookie Notice at any time. By visiting https://swag.live, setting up your SWAG account, or using the SWAG Services, you are accepting the information handling practices and storage and access of cookies as described in this Cookie Notice. We hope that this notice helps you understand, and feel more confident about, our use of cookies. If you have any further queries, please contact us by support@swag.live.

What is a Cookie?

Cookies are small text files that are stored on your device. They are widely used in order to make websites and software applications work, or work in a better, more efficient way. They can do this because websites and software applications can read and write these files, enabling them to recognize a particular device and remember important information that will make your use of a website or software application more convenient (e.g., by remembering your user preferences).

What Cookies do we use and why do we use them?

Below we list the different types of cookies we may use on the SWAG Services.

We use session cookies (that last until you close your browser) and persistent cookies (that last until you delete them from your browser, or until they expire in accordance with their lifespan). SWAG-originated persistent cookies on SWAG Services will have a maximum lifespan of thirteen months from the time you last used the SWAG Services. Cookies used to remember your privacy settings. We use first party and third party cookies. First-party cookies are created and accessed by the host domain - the domain the user is visiting, in this case, SWAG. Third-party cookies are those created and accessed by domains other than the one the user is visiting at the time.

Operational Cookies: These cookies are critical to the operation of the SWAG Services. These cookies are used, for example, to maintain your login state and remember your preferences. These cookies cannot be disabled without severely affecting your use of the SWAG Services.

Examples of cookies include the following:

Operational cookie examples

region: Region determination

country: Country determination

i18next: User preferences

_version: User last visit version

_clientId: User environment

token, refreshToken: Authentication & authorization

Analytics cookie examples

General Analytics e.g. utm_xxx

Google Analytics e.g. _ga, _ga_XXX, _gcl_au

Mixpanel e.g. mp_xxx

Advertising & Marketing cookie examples

TrafficJuncky e.g. d_fs , d_uid , d_uidb

How do I control Cookies?

All users can also enable Google’s browser extension to disable Google Analytics across any website that you visit. You may also refuse to accept cookies from the SWAG Services or Extension developers at any time by activating the setting on your browser which allows you to refuse cookies. Further information about the procedure to follow in order to disable cookies can be found on your Internet browser provider’s website via your help screen.

Legal Bases for Processing Your Personal Data

We process your personal data based on the following legal bases under GDPR:

Consent (Art. 6(1)(a)): For optional features such as social media login, non-essential cookies, marketing communications, or sharing data for personalized advertising. You can withdraw consent at any time through your account settings or by contacting us at support@swag.live, without affecting the lawfulness of processing before withdrawal.

Performance of a Contract (Art. 6(1)(b)): To create and manage your account, provide the Services (e.g., sending/receiving messages, photos, videos), handle customer support, complete transactions, and communicate about your orders or billing.

Legitimate Interests (Art. 6(1)(f)): To improve our Services (e.g., through analytics, surveys, and user behavior research), develop new features, prevent fraud or unauthorized activities, ensure device consistency, and provide interest-based advertising. We have conducted a legitimate interests assessment to ensure our interests do not override your rights and freedoms. You can object to this processing—see "Your Rights" below.

Legal Obligation (Art. 6(1)(c)): To comply with applicable laws, regulations, legal processes, or government requests, and to assist law enforcement.

For special categories of personal data (e.g., gender or data that may reveal sensitive information such as sexual orientation in the context of our adult-oriented Services), we rely on your explicit consent (Art. 9(2)(a)). We do not process such data without it.

Data Retention

We retain your personal data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law. For example:

Account information (e.g., username, email) is retained while your account is active and for up to 12 months after deletion for fraud prevention or legal compliance.

Content (e.g., messages, photos, videos) is retained as long as needed for Service delivery, typically until you delete it or for 6 months post-deletion for backup purposes.

Fraud-related data is retained for up to 5 years to prevent recurrences.

Analytics and cookie data is retained for up to 13 months, as per our Cookie Notice.

At the end of the retention period, we securely delete or anonymize the data. If you request erasure, we will comply unless retention is required by law.

International Data Transfers

Your personal data may be transferred to and processed in countries outside the EU/EEA, such as Taiwan or other locations where our servers or partners are based. These countries may not have data protection laws equivalent to GDPR. To ensure adequate protection, we use safeguards such as:

Standard Contractual Clauses (SCCs) approved by the European Commission.

Binding Corporate Rules (BCRs) where applicable.

Other mechanisms as required by GDPR (Art. 44-50).

For more details on transfers or copies of safeguards, contact us at support@swag.live.

Data Breaches

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours, as required by GDPR (Art. 33). If the breach is likely to result in a high risk, we will also notify affected users without undue delay (Art. 34), including details of the breach, potential impacts, and recommended actions.

Your Rights Under GDPR

If you are an EU/EEA resident, you have the following rights regarding your personal data:

Right of Access: Request confirmation of processing and a copy of your data.

Right to Rectification: Correct inaccurate or incomplete data.

Right to Erasure ("Right to be Forgotten"): Request deletion in certain circumstances (e.g., if data is no longer necessary or consent is withdrawn).

Right to Restriction of Processing: Limit processing while we verify your request.

Right to Data Portability: Receive your data in a structured, machine-readable format and transfer it to another controller.

Right to Object: Object to processing based on legitimate interests (e.g., direct marketing or profiling) or for public interest tasks.

Right to Withdraw Consent: At any time, for consent-based processing.

Rights Related to Automated Decision-Making: Not be subject to decisions based solely on automated processing (including profiling) that produce legal effects. We do not currently engage in such decisions, but if we do, you can request human intervention or challenge the decision.

To exercise these rights, contact us at support@swag.live with proof of identity. We respond within one month (extendable to two months for complex requests). Requests are free, but we may charge a reasonable fee for excessive or unfounded requests. You also have the right to lodge a complaint with your local data protection authority (find yours at https://edpb.europa.eu/about-edpb/about-edpb/members_en).

Data Protection Officer

We have appointed a Data Protection Officer (DPO) to oversee GDPR compliance, particularly given the nature of our Services involving sensitive data. You can contact our DPO at dpo@swag.live for any data protection concerns.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. For material changes affecting your rights, we will notify you in advance via email, app notification, or a prominent notice on our Services, at least 30 days before the changes take effect (unless required by law to implement sooner). Continued use of the Services after changes constitutes acceptance.

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