SWYP Privacy Policy

1. Types of Personal Data We Process

The categories of Personal Data we may process about you depend on the nature of your engagement with SWYP and may include:

• Personal details such as name, gender, date of birth/age, nationality, passport or national ID number, social security number, tax identification number.

• Contact details including address, email address, telephone number, and social media account information.

• Corporate details such as the name, place of registration, registration number, transparency register number, details related to articles of association, and other similar documents/certificates, as well as information pertaining to shareholders and/or beneficial owners, including their personal and contact details.

• Technical information about the devices (e.g., IP address) you use for communications, transactions, or interactions with SWYP's services.

• Details concerning your cryptocurrency token transfers, including SWYP tokens, as long as these transactions are publicly viewable on the respective cryptocurrency platform.

2. How We Collect Your Personal Data

We may collect your Personal Data from various sources, including:

• When you contact us via email, our contact form, telephone, or any other means of communication.

• In the normal course of our relationship with you, such as during business communication, negotiation proceedings, etc.

• When you voluntarily make your Personal Data public, including through social media profiles.

• When we receive your Personal Data from third parties who legally provide it to us, such as credit reference agencies or law enforcement agencies.

• When you visit any of our websites or use features/resources available through them. Your device and browser may automatically provide certain information (e.g., device type, IP address, browser settings) during your website visits.

• When you submit your resume/CV to us for a job application.

• When you subscribe to any of our social media accounts.

3. Creation of Personal Data

In the course of your interactions with SWYP, we may also generate Personal Data about you, such as records of your interactions with us and details of your transaction history.

4. Purposes for Processing Your Personal Data

We process your Personal Data to provide, maintain, and enhance our services, particularly in the context of further developing and improving the SWYP technology and associated technologies. Additionally, we may use your Personal Data to communicate with you about upcoming events, provide news and updates related to SWYP, respond to your inquiries, evaluate job applications, provide contracting quotes, assess partnership proposals, or consider funding requests (including those submitted to the Ecosystem Development Fund), and for other routine business activities aligned with our nonprofit foundation charter.

5. Legal Basis for Processing Personal Data

In processing your Personal Data for the purposes described in this Policy, we may rely on one or more legal bases, depending on the circumstances:

• We have obtained your explicit prior consent for the processing, as per Art. 6(1)(a) GDPR (this legal basis is only used for entirely voluntary processing).

• The processing is necessary for the performance of a contract to which you are a party, as per Art. 6(1)(b) GDPR.

• The processing is required to comply with applicable law, as per Art. 6(1)(c) GDPR.

• The processing is necessary to protect vital interests, as per Art. 6(1)(d) GDPR.

• We have a legitimate interest in conducting the processing for managing, operating, or promoting our business, provided that this legitimate interest is not overridden by your interests, fundamental rights, or freedoms, as per Art. 6(1)(f) GDPR.

When we involve third-party processors in providing services and fulfilling contractual obligations that require the sharing of Personal Data, we enter into data processing agreements with these third parties in accordance with Art. 28 of the European General Data Protection Regulation ("GDPR"). Additionally, where required, we implement further appropriate safeguards as per Art. 46-49 GDPR. You can request a list of third-party processors to which we disclose your Personal Data by emailing privacy@swyp.foundation.

6. Processing of Special Categories of Personal Data

• We do not seek to collect or process your Sensitive Personal Data unless

• The processing is required or permitted by applicable law.

• The processing is necessary for establishing, exercising, or defending legal rights.

• We have obtained your explicit consent, as per applicable law, before processing your Sensitive Personal Data (this legal basis is only used for entirely voluntary processing).

7. Consequences of Not Providing Your Personal Data

Your Personal Data is necessary for us to provide our services and fulfill our contractual obligations to you. Without providing this Personal Data, we may not be able to deliver the services you seek.

8. Consent and Withdrawal

Any consent you provide is voluntary. If you grant your consent, you have the right to withdraw it at any time by contacting us at the address provided below. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to withdrawal. This provision applies only to entirely voluntary processing, not to processing that is necessary or obligatory in any way.

9. Data Erasure

We erase your Personal Data when it is no longer necessary for the purposes outlined above and when further storage is neither required nor permitted by applicable laws. We also erase your Personal Data upon your request, provided that further storage is not mandated by applicable laws.

10. Cookies

We use cookies on our websites. "Cookies" are small pieces of information sent from some websites to your web browser to recall information about previous browsing activities. We may use cookies to identify the browser you are using to ensure proper website display. Cookies are also used in various places on our website to track your visit and enhance website design efficiency.

We use cookies on our websites. "Cookies" are small pieces of information sent from some websites to your web browser to recall information about previous browsing activities. We may use cookies to identify the browser you are using to ensure proper website display. Cookies are also used in various places on our website to track your visit and enhance website design efficiency.

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11. Use of Third-Party Tools

To enhance our websites and analyze user behavior, we have integrated tools from other companies into our websites. In certain cases, we may have implemented content from other websites.

12. Your Rights Related to Data Privacy

You have several rights concerning your personal data, including:

• The right to access (Art. 15 GDPR): You can request confirmation of whether your personal data is being processed and receive comprehensive information about this data.

• The right to rectification (Art. 16 GDPR): You can request the correction of inaccurate personal data without delay.

• The right to erasure (Art. 17 GDPR): You can request the erasure of your personal data without delay.

• The right to restriction of processing (Art. 18 GDPR): You can obtain a restriction of the processing of your personal data, including the right to prevent further processing during the period required for us to verify data accuracy.

• The right to data portability (Art. 20 GDPR): You can receive your personal data in a commonly used, machine-readable format for potential transfer to another controller, as long as this transfer is not related to performing public tasks.

• The right to object (Art. 21 GDPR): You can object to further processing of your personal data in certain situations. In such cases, we will not process your data further unless justified by public tasks or public and private interests.