Privacy Policy

Introduction

This Privacy Policy, together with our Terms and Conditions and other applicable policies, governs the collection, processing and use of your Personal Data by Swapteria.

Swapteria is operated by HRDT FINANCE LLC, registered at 1001 S Main St, STE 49, Kalispell, Montana, USA.

We collect and use Personal Data of users, authorised persons, website visitors and anyone contacting our support team in order to provide our services, improve our platform and comply with legal and regulatory obligations.

This Privacy Policy is designed to reflect applicable data protection principles, including transparency, fairness, security, purpose limitation and data minimisation.

What Data We Collect About You

1. Information you give to us

You may provide us with information by filling in forms on our website, opening an account, verifying your identity, contacting support, or communicating with us by email or other means.

• first and last name;
• residential address and citizenship;
• email address and phone number;
• date and place of birth;
• government-issued identity document;
• photos or videos used for verification purposes;
• tax residence;
• PEP and sanctions screening results;
• source of funds and source of wealth information;
• bank details and payment information;
• login information;
• support inquiries;
• other information required for AML, CTF and KYC compliance.

2. Information we collect about you

When you visit our website or use our services, we may collect technical and usage information automatically.

• IP address;
• browser type and version;
• time zone, operating system and device information;
• website usage data;
• pages viewed and links clicked;
• download errors and response times;
• approximate location data;
• transaction and service usage data.

3. Information we receive from other sources

We may receive information about you from third parties, including business partners, identity verification providers, compliance service providers, analytics providers and financial institutions.

Swapteria does not knowingly collect information from persons under the age of 18.

Use of Cookies

Our website may use cookies to distinguish you from other users, improve your browsing experience and help us analyse website performance.

We may use the following cookies:

• Strictly necessary cookies — required for the operation of the website.
• Analytical cookies — used to understand how visitors interact with the website.
• Functionality cookies — used to remember your preferences.
• Targeting cookies — used to make content more relevant to your interests.

We may use Google Analytics or similar tools. You can block cookies through your browser settings.

Why We Use Your Personal Data

1. To provide services

• to create and manage your account;
• to provide access to our platform;
• to process transactions;
• to secure our website and services;
• to respond to support requests.

2. To improve our services

• to improve website functionality;
• to analyse service usage;
• to improve user experience;
• to evaluate the effectiveness of communications and materials.

3. For compliance and security

• to verify user identity;
• to comply with AML, CTF and KYC requirements;
• to prevent fraud and misuse of our services;
• to respond to lawful requests from authorities;
• to manage legal, regulatory and operational risks.

Your Personal Data Disclosure

We may share your information with selected third parties where necessary for the provision of services, compliance, security, analytics or legal purposes.

• identity verification and compliance providers;
• payment and banking service providers;
• business partners and subcontractors;
• analytics and technical service providers;
• regulators, courts or law enforcement where required by law.

We do not sell your Personal Data.

Security and Storage of Personal Data

We implement appropriate technical and organisational measures to protect your Personal Data against unauthorised access, loss, misuse, alteration or destruction.

Access to Personal Data is restricted to authorised personnel, service providers and contractors on a need-to-know basis and subject to confidentiality obligations.

However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security against unauthorised access beyond our reasonable control.

Basis for Personal Data Processing

We process your Personal Data only where we have a lawful basis to do so. Such basis may include:

• your consent;
• performance of a contract with you;
• compliance with legal obligations;
• legitimate business interests;
• fraud prevention and security purposes;
• regulatory compliance and risk management.

Your Rights

Depending on your jurisdiction, you may have certain rights regarding your Personal Data, including:

• right to be informed;
• right of access;
• right to rectification;
• right to erasure;
• right to restriction of processing;
• right to data portability;
• right to object;
• right not to be subject to solely automated decision-making.

Retention of Personal Data

We retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected and to comply with legal, regulatory, audit, accounting or reporting obligations.

In accordance with applicable record keeping obligations, we may retain account information and Personal Data for at least five (5) years after the end of the customer relationship, unless a longer period is required by law or regulatory requirements.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time by posting the updated version on our website. The updated version will apply from the date of publication.

Your continued use of our services after publication of the updated Privacy Policy constitutes acceptance of the revised terms.

Contact Us

If you have any questions, comments or requests regarding your Personal Data, please contact us at: [email protected].