At Popswap, your privacy is a top priority. We appreciate that you trust us with your personal data and we intend to always keep that trust. This starts with making sure you understand what personal data we collect, why we collect it, how it is used and your choices regarding your information. In this Privacy Policy, we describe our privacy practices.

1. Who we are

The company responsible for processing your personal information under this Privacy Policy (the “controller”) is PopSwap AB, company registration no 559226-0359.

2. Information we collect and how we use it

In order to provide our services and the best possible user experience we collect and process information about you. We collect information you give us, information we collect from third parties as well as information generated when you use our services. For additional information, please see below.

Information you give us

Information we receive from others

Information collected when you use our services

Usage information We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive) in order to help improve our services.

Device information We collect information from and about the device(s) you use to access our services, in order to facilitate trade of items with other users as well as to improve our services, including:

- hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);

- information on your wireless and mobile network connection, like your service provider and signal strength;

- information on device sensors such as accelerometers, gyroscopes and compasses.

3. Why we process your personal data

Performance of a contract

We process the information you provide when creating an account with us as well as the payment information we collect from partners when you subscribe to a paid service through a platform, such as an app-store, for the purpose of performing a contract with you.

Balance of interests

We process other information we collect from you, that we collect from others and that we collect when you use our services on the basis of a balance of interests.

Our legitimate interest is to facilitate your trade of items through the app, improving our app and services and to exercise and protect our rights in case of legal claims. Providing your personal data is not a legal requirement, however providing the information will help us improve your user experience and facilitate trades with other users.

4. How we share information

With other users

You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that you only share information that you’re comfortable being viewable by others since neither you nor we can control what others do with your information once you share it.

With our service providers and partners

We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.

We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.

We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.

For corporate transactions

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

When required by law

We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

To enforce legal rights

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With your consent or at your request

We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

5. Transfer of personal data to third countries

As a principle rule, we, our suppliers and our partners only process your personal data within the EU/EEA. In cases where personal data is processed outside the EU/EEA, such processing is either based on a decision from the Commission establishing that the country in question ensures an adequate level of protection or appropriate safeguards that ensure that your rights are protected.

6. Processing of personal data through cookies

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools.

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Tinder, do not currently respond to DNT signals.

7. How long we keep your information

Information we process for the purpose of performing a contract with you is as a principle processed during the period of time it is necessary for us to administer the contractual relationship.

Information we process on the basis of a balance of interests is as a rule processed for as long as we have a right to do so according to our legitimate interests. Information necessary for facilitating user trades and information you share with others is as a principle processed for as long as you have an account or until you chose to delete it yourself. Information collected in surveys or focus groups, collected from your device or other information necessary for improving our app and services is as a principle processed only for as long as we need it to evaluate and implement changes to our app and services. We may however process your information for a longer period in order to comply with legal requirements, or because we have a right to do so according to our legitimate interests.

8. Your rights

Below you can find information about your rights as a user regarding our processing of your personal data. You are welcome to contact us if you wish to exercise your rights (please see contact details below).

Right to withdraw your consent and object to the processing

You may at any time withdraw the consent you have given us, either as a whole or partly, with effect from the day of the withdrawal.

You may object to our processing of your personal data for marketing purposes. We will then cease to process your personal data. You also have the right to object to the processing of your personal data on the basis of a balance of interests.

Right to access

You are entitled to request information about which personal data we process about you and how the personal data is being processed. You also have the right to request a copy of the personal data we process about you.

Right to rectification

You have the right to without unnecessary delay get inaccurate information corrected and to get incomplete information completed by providing us with correct information.

Right to erasure (right to be forgotten) and limitation

You have the right to at any time request that your data is erased, for example if the processing is no longer relevant in relation to the purpose the information was collected for, or if you object to processing which is based on our legitimate interests (marketing).

You may also request to have certain processing of your personal data restricted, for example if you object to the accuracy of the data.

Right to data portability

If you have given your consent to the processing or if the legal basis for processing is to fulfil an agreement with you, you have the right to obtain the personal data you have provided us with in a structured, commonly used and machine-readable format and have the right to transmit such to another controller, or get our assistance to transmit the data to another controller when technically feasible.

Right to object

If you have any complaints regarding our processing of your personal data, you have the right to send a complaint to the Swedish Data Protection Authority (www.imy.se).

9. How to contact us

If you have questions about this Privacy Policy, you can e-mail us at contact@popswap.app.