Swash Data Tech Limited (“Swash”, “the app”, “we”, “us” or “our”) incentivises people to earn for being active online by granting permission to share their information and enabling them to engage in various data sharing activities. When businesses purchase data, insights, or advertising space, the user is automatically rewarded for their contributions.

At Swash, we hold the privacy of our users, denoted as “users,” “you,” or “your,” in the highest regard. We aim to provide you with a clear understanding of what information we collect, how we use it, and how we safeguard your data. We strongly encourage you to review this privacy policy in detail to ensure your use of Swash aligns with your preferences. This document, known as the “Privacy Policy” or simply “Policy,” delineates our practices concerning the collection, utilisation, disclosure, and protection of your information as you engage with our services. It also outlines your rights as dictated by applicable laws. We urge you to read and comprehend this Privacy Policy, as it will empower you to make informed choices regarding the sharing of your information with Swash.

This Policy applies to the information collected when you utilise Swash's application and extension. These include the browser extension compatible with popular browsers such as Mozilla Firefox, Google Chrome, Microsoft Edge, Brave, Kiwi, Yandex, and Safari, as well as our mobile application available on iOS and Android devices.

Our services include:

• Swash apps on web browser and mobile devices;
• Web and mobile applications, websites (including https://swashapp.io and all subdomains of https://swashapp.io), blogs, forums, and any other media channels or products;
• Swash Earn; a dashboard in which our partners can present their offers to Swash users;
• Swash Ads’ ad space hosted by Swash and our partners that contain an advertisement served by or on behalf of Swash;
• Products that are integrated into third-party apps and sites, like ads;
• A page on the Swash domain, or in the Swash mobile app, or any other Swash products, including those that may be introduced from time to time in the future (collectively referred to herein as the “Services”).

By using Swash, you grant your consent for the processing of your personal data in accordance with this policy.

It is essential to note that Swash is not intended for use by children, and we do not knowingly collect data from individuals under the age of 18. This restriction is in place to uphold the privacy of children. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us at[email protected]and we will take steps to close the associated accounts, delete the information, and prevent the user from continuing to use our Services.

Swash has completed a full Data Protection Impact Assessment and is registered with the Information Commissioner’s Office, bearing registration number ZB125042. Additionally, Swash is a recognised member of the Data & Marketing Association.

The Swash extension serves the purpose of gathering and consolidating data related to your online browsing activities and your use of digital devices and services. To achieve this, two distinct versions of the extension have been developed: one tailored for the Firefox browser and another for all browsers based on Chromium, and Safari. In addition, we have created equivalent app-based implementations for both Android and iOS platforms that operate seamlessly on these devices.

We employ various methods to gather data from and about you, including:

Direct Interactions

You may share your identity data and contact information by completing forms or engaging in correspondence with us via post, email, or other means. This includes personal data you provide when you:

• Apply to receive, participate, and interact with our products or services on the Website or within the App;
• Create an account with Swash;
• Use our products and services;
• Submit a query or request to us;
• Subscribe to our newsletters and publications;
• Request marketing to be sent to you;
• Seek support services;
• Complete a survey;
• Comlete an offer; or
• Provide feedback or contact us.

Automated Technologies or Interactions

As you engage with our Website or Services, we automatically collect technical data related to your devices, computers, equipment, browsing behaviours, and patterns. We obtain this information by:

• Running a JavaScript code in the context of a specific page;
• Capturing requests sent to/responses received from specific devices and domains;
• Reading your browser information;
• Tracking your use of our websites and mobile applications;
• Receiving data from Swash’s advertisement and survey, and offer partners;
• Capturing activities on mobile applications.

Please consult the “Your Privacy Controls” section of this policy to review your control options. It is important to note that you have the freedom to opt in or out of using Swash at any time, and you can make choices about the information you opt to share depending on the products and services you use.

Third Parties or Publicly Available Sources

We may receive information about you from various third parties, including:

• Public sources.
• Examination of both public and private blockchains.
• Third parties who are authorised to share such information with us.
• Third parties that we utilise for marketing and communication purposes, which may include Google Analytics and Brevo.
• When you apply for a job or apply to become an ambassador with us.

Swash operates by collecting, utilising, and distributing aggregated data, encompassing statistical and demographic information. Should you grant Swash permission, your user-level data may also be shared. By default, this user-level data remains entirely anonymous.

Aggregated data might originate from your personal data, but it's essential to clarify that Swash will never sell your PII to third parties. There are instances where legal requirements may oblige us to gather specific forms of personal information about you.

Where we collect personal information from you, we will generally do so ourselves. Nevertheless, there may be cases where we acquire personal data from a third party, whether through your representatives, contractors providing services to us, or third parties who recommend our products or services to you based on your potential interest.

We are committed to protecting your data rights. It’s important to note that Swash is not responsible for any misuse of data by third parties. However, it is mandatory for these third parties to enter into the Swash Data Processing Agreement, which outlines the specifics of their intent to procure data. This arrangement empowers you to exercise your data rights under GDPR.

The personal demographic information we gather includes the following:

When you use Swash's products, the information collected varies depending on your usage of the products and your internet browsing activities while Swash is active. For instance, the data points gathered when you are on a shopping website will differ from those collected on an audio website, reflecting the distinct nature of your interactions with these websites. This data will also vary if you choose to participate in Swash Earn by completing tasks at your discretion.

Below, you will find a comprehensive list of the distinct categories Swash collects and the types of data obtained from each:

Clickstream Data:

Clickstream data includes the following data from all websites:

• The websites you visit
• Whether you bookmark a website
• Information on the pages you visit

Shopping Data:

Shopping data includes data from popular shopping websites, such as Amazon and eBay. This includes information like:

• The pages you visit
• What you search for on these sites
• Search suggestions you have selected
• Search results presented to you
• Search results you have clicked on
• The items in your cart
• The items in your wishlist

Search Data:

Search data includes data from popular search engines, such as Google and Yahoo. This includes information like:

• What you search for
• The results presented to you
• The results you click on
• The ads that you click on

News Data:

News data includes data from popular news sites, such as the BBC and CNN. This includes information like:

• The pages you visit
• The news items you click on
• Content of the news items of you click on

Social Data:

Social data includes data from popular social media sites, such as Facebook and X (formerly Twitter). This includes information like:

• What you search for
• The pages you click on
• Posts you publish
• Games, music, movies, television, and books you ‘like’
• Your ‘follow’ and ‘unfollow’ actions
• Your ‘mute’ and ‘unmute’ actions
• Your ‘likes’ and ‘reposts’

App Usage Data:

• App name
• App session’s start time
• App session’s end time

Media Data:

• Media player used for playing the media
• Media title
• Media description
• Channel name in which media is played
• Overall duration of the media
• Duration of the engagement in the media

Audio Data:

Audio data includes data from popular audio media sites, such as Spotify. This includes information like:

• Songs and albums you save
• Current playlists
• Currently playing
• Recently played
• Artists you follow
• Listening duration
• Playback information

Swash uses your data to create a data product to be sold on your behalf. Your data is collected and aggregated into a comprehensive data pool, which encompasses information from all Swash users. When this data product is purchased, the value it generates is automatically apportioned to you and added to your earnings balance within your Swash account.

By using Swash, you are agreeing to the collection and use of your information via the products and services described in this policy. Within the Swash solutions - which includes, but is not limited to, the Swash extension and mobile app, there are a variety of services and features that collect your data, browsing activities, ads engagement, and survey responses.

Provide Our Services

We use your information to provide our services, such as collecting your data to compensate you for your contributions or presenting you with advertisements and Earn opportunities that you can choose to engage with at your discretion.

Maintain & Improve Our Services

We use your information to ensure the proper functioning of our applications and services. This includes troubleshooting issues that you may report. Our sources of information may include data from researchers, publicly available datasets, and support from professional and charitable groups engaged in research.

Additionally, we use your information to enhance our services, better understand user experience, and identify areas that require improvement, such as features that may be challenging to access or that don't load correctly so we can improve the design and functionality of your experience.

Develop New Services

We use the information collected in our existing services to aid in the development of new ones. For instance, by analysing user responses to Swash Earn surveys, we gain insights into the types of partnerships that can provide more offerings to our users. User feedback and contributions from the Swash community, including proposals submitted to the Swash DAO, also guide us in determining which features to prioritise.

Provide Personalised Services, Including Content and Ads

We use the information you provide to tailor our services to your preferences. For instance, if you have opted to receive updates from us, we may offer relevant email newsletters. Depending on your settings, we may also display ads in line with your preferences. You can find more information on privacy controls in the “Your privacy controls” section of this policy.

Measure Performance

Data is utilised to measure and analyse how our products are used and how our marketing efforts resonate with Swash users. For instance, we analyse data related to your visits to our websites to enhance Swash product design and refine our product messaging.

Communicate with You

We communicate with you based on the information you've shared with us, such as contact information provided in your profile or via contact forms. We may use the information we collect, such as your email address, to engage with you directly. This may include sending notifications of new product updates or informing you about upcoming changes or service enhancements. If you reach out to Swash, we will maintain a record of your request to assist in resolving any issues you may encounter.

Protect Swash, Our Users, and the Public

The information we gather serves to safeguard individuals from harm and ensure the safety and reliability of our products. This involves the detection, prevention, and response to instances of fraud, abuse, security threats, and technical problems that may pose risks to Swash, our users, or the public.

You have choices when it comes to the information Swash collects. This section outlines the various options available to you for deciding what information you wish to share or withhold. Regardless of your choices, Swash will consistently adhere to the protocols defined in this policy.

Enable or Disable Swash

When you use Swash, you retain the ability to enable or disable it at any time via your browser toolbar or your device settings. When Swash is disabled, it cannot collect any information. On mobile devices, you can disable Swash by revoking the permissions you previously granted by visiting your device settings.

Delay Data Sending

You can select the duration for which you would like to delay sending your information to the Swash dataset. This feature allows you to preview the data before it is sent and provides you with the option to cancel the transmission of any information you prefer not to share.

Text Masking

Text masking allows you to actively obscure specific text elements, such as characters, digits, words, or combinations of words, within the data collected by Swash. This feature can be employed to mask various types of information like your name, phone number, or email.

Note: Text masking is an additional feature and is not obligatory for preserving your privacy according to this privacy policy. However, it can be useful for safeguarding specific details you want to ensure are excluded from the dataset, providing an extra layer of security.

Exclude URLs

You have the option to select which URLs you wish to exclude from data capture. This feature is valuable if you wish to ensure that no information is collected while you browse specific websites. You can modify your list of excluded URLs at any time by visiting the Settings section of your Swash account.

Participate in Surveys

Participating in surveys is entirely voluntary. You can choose not to respond to specific questions or opt out of surveys altogether. The decision of when and how many surveys you participate in is entirely up to you. Regardless of your choice to complete surveys, you can continue to use the remaining features of Swash as usual.

Manage Advertisements

You have the liberty to decide whether you want to receive advertisements from Swash Ads, as it is not compulsory. You can also choose to opt in or out of specific types of ads by adjusting the toggles in your settings. Regardless of your preference for receiving ads, you can still use the other features of Swash without any disruption.

Managing, Reviewing, and Updating Your Information

Captured Data

When you're signed in, you have the ability to easily access and update the information that has been collected about you. You can do this by navigating to the 'Data' page in your Settings. On this page, you can configure a delayed timer, allowing you ample time to review and remove any information that you prefer not to share.

Ad Settings

You have the option to control your preferences regarding the advertisements you see on Swash and on the websites and applications where Swash ads are displayed. You can make choices about whether you want to receive ads and the types of ads you wish to view.

About You

Manage your personal info in your Swash profile at any time by visiting your settings.

Here are some of the ways Swash uses your information:

Facilitating Payments

We use your information to enable you to receive payments for the data you contribute.

Content Delivery

Your information is used to provide you with content from the data products you've acquired or subscribed to.

Feedback and Engagement

We seek your input, feedback, and suggestions regarding Swash's functionality.

Communication

We notify you of changes, upgrades, or issues related to the functionality of Swash.

Requested Communications

We send you communications that you've specifically requested, which may be of interest to you.

Personalised Advertising

Your information is used to help Swash deliver more relevant advertisements based on your interests, preferences, and demographics. This personalisation enhances your advertising experience and boosts the effectiveness of Swash's advertising campaigns.

Ad Performance Analysis

We analyse the data we gather to evaluate the performance of Swash Ads, optimise targeting strategies, and gauge the success of advertising campaigns.

Survey Insights

Survey responses are analysed in an aggregated and anonymised form to generate insights, reports, and statistical data for internal use, which, in turn, contributes to the enhancement of Swash's programs and services.

The data collected through surveys and advertisements serves the purpose of research, analysis, and the improvement of our products, services, and user experience. Swash may employ aggregated and anonymised survey data for internal objectives or share it with third parties in a manner that does not personally identify individuals.

Swash does not disclose your information to external companies, organisations, or individuals except in the following circumstances:

With Your Consent

We share your information outside of Swash when we have your explicit consent. Swash operates by allowing you to share your data in an aggregated and anonymised manner with third parties. Additionally, you have control over reviewing and managing the data captured in the 'Data' section of the Swash product. However, if you opt to share additional information, such as through Swash Earn, you will need to grant permission to those third parties before your information is shared. We also provide you with the tools to oversee and manage the data collected through the app.

For External Processing

We may provide information to our partners and other trusted businesses or individuals to process it on our behalf, following our instructions and in adherence to our Privacy Policy. This involves employing service providers for tasks like data storage, product and service delivery, process improvement, and customer and user support. We exercise careful selection when engaging these companies and share only the necessary information required to facilitate their services.

For Legal Reasons

We will disclose personal information outside of Swash if we have a good-faith belief that such access, use, preservation, or disclosure is reasonably necessary to:

• Comply with applicable laws, regulations, legal procedures, or enforceable governmental requests.
• Enforce applicable Terms of Use, including the investigation of potential violations.
• Respond to legal requests, such as search warrants, court orders, production orders, or subpoenas, originating from third parties like civil litigants, law enforcement, and other government authorities.
• Detect, prevent, or address security or technical issues.
• Safeguard the safety, security, and integrity of Swash, our users, employees, property, and the public.

In the event of a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, purchase or sale of assets, transition of services to another provider, or sale of assets involving Swash, we will continue to uphold the confidentiality of your information. Affected users will be notified before their personal information is transferred or subjected to a different privacy policy. If necessary, your information may be shared with the successor entity or third party. When required by law, you will be informed through email and/or prominent notices on our Services regarding any changes in ownership or the use of your personal data, along with any choices you may have regarding your data.

You can export a copy of your information or delete it from your Swash account at any time.

You can export a copy of content in your Swash account if you want to back it up or use it with a service external from Swash.

To delete your information, you can:

• Remove Swash from your device to prevent further collection of your information or
• Opt-out of specific Swash products by ceasing to interact with them. For example, for Swash Earn this would mean not actioning on any tasks.
• Delete your Swash account by writing to us

We retain information for as long as it's necessary to deliver our products, adhere to legal requirements, or safeguard our interests or the interests of others. The duration for which we hold your personal data is determined on a case-by-case basis. Here are the factors we consider when making these decisions:

• Operational Necessity:We retain some of your information to ensure the smooth operation of your account;
• Purpose and Feature:The length of data retention is influenced by the specific feature we use it for and how that feature operates;
• Legal Obligations:We retain data for the time required to meet legal obligations;
• Legitimate Purposes:We may hold data for other valid reasons, including preventing harm, investigating possible violations of our terms or policies, enhancing safety, security, and integrity, or protecting our rights, property, or products.

Retention requirements vary depending on the country, and our internal policies are designed around how information must be utilised. Considerations include when the information was collected or created, its necessity for providing our services, legal compliance (including AML/KYC requirements), and the protection of safety, security, and integrity.

Once a retention period expires, or if personal data storage is no longer relevant, we routinely block, delete, or erase the data in accordance with our retention schedule and applicable laws. Additionally, we delete data that's no longer required for the above purposes when you close your account or request the deletion of your information.

it's important to note that while our systems are designed to automatically carry out deletion procedures, we cannot guarantee a specific timeframe for deletion. Legal requirements may necessitate data retention, and we may suspend deletion practices if we receive valid legal processes requesting data preservation, reports of abuse, or violations of our Terms of Service, or if your account is flagged by our systems for misuse or other violations. Certain data may also be retained in backup for a limited period or as required by law.

We will retain your personal information as long as it remains relevant to the purpose for which it was collected or provided, up to a maximum of 18 months for collected data that has not been shared. However, if you withdraw your consent before that, Swash will no longer retain the data.

You have the option to request the closure of your Swash account at any time. Upon receiving your request, we will promptly close your account. If you have entered into a contract with a third-party provider, the contract may include additional obligations regarding the duration of personal data retention, as mentioned above.

How to Exercise Your Rights and Contact Swash

If European Union (EU) or United Kingdom (UK) data protection laws apply to the processing of your information, we offer the controls described in this policy to allow you to exercise your rights. These rights include requesting access to, updating, removing, and restricting the processing of your information. You also have the right to object to the processing of your information or export your data to another service.

For additional questions or requests related to your rights, you can get in touch with Swash and our data protection office. If you have concerns about your rights under local law, you can also contact your local data protection authority.

Data Controller

The data controller responsible for processing your information is Swash Data Tech Limited located at 71-75 Shelton Street, Covent Garden, London, United Kingdom WC2H 9JQ.

Your Rights

You have various rights concerning your personal data. Please note that these rights may be subject to qualifications or specific requirements arising from applicable laws, which are not fully described here.

Right to Access Your Personal Data

You have the right to confirm whether your personal data is being processed by Swash and to access your personal data, including information about the purposes of processing and the types of personal data involved.

Right to Rectification

You can request Swash to correct any inaccurate data about you.

Right to Erasure

In certain situations, such as when data is no longer necessary or processed unlawfully, you have the right to request the erasure of your information.

Right to Restriction of Processing Your Personal Data

You can restrict the processing of your personal data in specific situations, which generally means Swash can store the data but not use it. For example, if you believe the personal information we hold about you is inaccurate, you can exercise this right until we verify its accuracy.

Right to Object to Processing Your Personal Data

At any time, you have the right to object to the processing of your personal data for direct marketing purposes. You can also object to processing based on Swash's legitimate interests, depending on your specific circumstances.

Right to Data Portability

You have the right to obtain your personal data in a structured, commonly used, and machine-readable format and transfer it to another data controller if Swash processes your personal data based on your consent or a contract. For this right to be available to you, Swash’s processing of your personal data must take place by automated means.

Right to Withdraw Your Consent

If Swash processes your personal data based on your consent, you have the right to withdraw your consent at any time. You can do so by sending an email to [email protected]. You can also manage your consent preferences by adjusting the relevant modules in the Data section of settings in the Swash application. Withdrawing your consent does not affect the lawfulness of the processing of your personal data based on consent before its withdrawal.

Right to Make a Complaint with the Data Protection Authorities

You can make a complaint to the data protection authorities about our processing of your personal information. In the UK, you can lodge a complaint with the Information Commissioner’s Office (ICO) here https://ico.org.uk/make-a-complaint/ or in writing to Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. In the EU, you can complain with the data protection authority of the EU member state where you have your permanent residence or where you work, or where you find that a potential breach with regard to your data has occurred.

To support these rights, upon request and in compliance with applicable law, Swash will provide information about whether we hold any of your personal data when you contact us as outlined in the “How to Contact Swash with Questions” section of this policy. You can update, correct, or delete your information at any time by logging into your account and adjusting your preferences. For your privacy and security, we may take steps to verify your identity before fulfilling your request. We may decline your request if we are unable to verify your identity.

When This Policy Applies

This Privacy Policy is applicable to all the services provided by Swash Data Tech Limited and its affiliates. These services encompass those offered on third-party websites, including advertising services. However, please note that this Privacy Policy does not apply to services that have distinct privacy policies that do not integrate with this Privacy Policy.

This Privacy Policy does not apply to:

• The information practices of other companies and organisations that promote Swash's services.
• Services provided by other companies or individuals, including products or websites they offer that may include Swash's services (where this policy applies), or products or websites presented to you in search results or linked from our services.

Changes to This Policy

Swash may periodically update this privacy policy. Any changes will be communicated to you when you access the Privacy Policy on this page. We will not diminish your rights under this privacy policy without your explicit consent. It is advisable to review this Privacy Policy at regular intervals for any updates. Policy changes become effective once they are posted on this page. In case of significant changes, we will provide a more conspicuous notice, which may include email notifications regarding Privacy Policy modifications.

Third-Party Links

The Swash website may include links to third-party websites, plug-ins, and applications. Clicking on these links or enabling these connections may permit third parties to collect or share information about you. Swash does not have control over these third-party websites and is not responsible for their privacy policies. When you navigate away from the Swash website, extension, or application, it is advisable to review the privacy policy of each website you visit to stay informed about your data rights.

The data collected by Swash may be transferred and stored on storage nodes located outside of your jurisdiction, where data protection laws may vary.

If personal information is transferred from an EU country to a location outside of the European Economic Area (EEA), this transfer will only occur if the EU Commission has confirmed that the third country offers an adequate level of protection as per the EU General Data Protection Regulation (679/2016). If such confirmation has not been granted for the specific country in question, the transfer will adhere to the EU Commission's standard contractual clauses for data transfers.

If you require further information regarding the specific mechanisms employed when transferring your personal data outside of the EEA, please do not hesitate to contact us by submitting a request here:https://support.swashapp.io/hc/en-us/requests/new

Swash Data Tech Limited acts as the data controller and is responsible for your data. Swash is registered with the Information Commissioner's Office in the United Kingdom, bearing registration number ZB125042. To oversee inquiries related to this privacy policy, Swash has appointed a Data Protection Officer (DPO).

If you have any questions regarding this privacy policy or wish to exercise your legal rights, please reach out to the DPO using the following contact details:

• Full name of legal entity: Swash Data Tech Limited
• Contact form:https://support.swashapp.io/hc/en-us/requests/new
• Website:https://swashapp.io

Swash has conducted a comprehensive Data Protection Impact Assessment and holds registration with the Information Commissioner's Office under registration number ZB125042. Furthermore, Swash is an accredited member of the Data & Marketing Association.

For any inquiries, please contact the Data Protection Officer for Swash Data Tech Limited using the information provided above. You also retain the right to file a complaint with the Information Commissioner's Office.

Under relevant data protection legislation, companies are required to establish a legal basis for the processing of personal data. “Processing personal data” encompasses the various ways data is collected, used, and shared, as outlined in other sections of this Policy.

The processing of your personal data is deemed necessary for the execution of the contractual relationship existing between you and Swash.

We may exclusively employ your information when a valid “legal basis” exists. The choice of legal basis depends on the purpose for which we use your information. These legal bases include contractual necessity, legitimate interests (either ours, yours, or those of another party), consent, adherence to a legal obligation, carrying out a task in the public interest, and safeguarding vital interests.

We process your information based on the following legal grounds as described in this policy:

Consent:

We seek your explicit consent to process your information for specific purposes, and you have the right to withdraw your consent at any time. Your consent is obtained, for instance, when you sign up for Swash, ensuring you have a clear understanding of how Swash operates.

As outlined in the “How your information is shared” section, your personal information is shared outside of Swash only when we have your consent. We provide you with controls to review and manage sites that have access to your data in your Swash Account.

Legitimate Interests:

We process your information to pursue our legitimate interests and the interests of third parties, with appropriate safeguards to protect your privacy.

This includes processing your information for purposes such as:

• Providing, maintaining, and enhancing our services to meet your requirements when using Swash;
• Developing new products and features that benefit you and other stakeholders;
• Analysing how people utilise our services to ensure and enhance service performance;
• Customising our services to offer you an improved user experience;
• Marketing to keep you informed about our services;
• Providing advertising if you opt in to this feature;
• Detecting, preventing, or addressing fraud, abuse, security, or technical issues with our services;
• Protecting against potential harm to the rights, property, or safety of Swash, our users, or the public, as required or permitted by law, which may include disclosing information to government authorities;
• Conducting research to enhance our services for you and the benefit of the public;
• Enforcing legal claims, including the investigation of potential violations of applicable Terms of Service.

Service Provision:

We process some data to provide services that you've requested. For example, when you sign up for Swash, we ensure you are informed about how Swash operates, and seek your consent to proceed.

Legal Obligations:

We process your data when we have a legal obligation to do so, such as responding to legal processes or enforceable governmental requests.

The legal basis for processing your information is determined by the specific purpose of the processing and the requirements of applicable laws.