Privacy policy

User - an individual who has reached the age of majority, capable of acquiring civil rights through his actions and independently exercising them, as well as creating civil responsibilities for himself, independently fulfilling them and being liable for failure to fulfil them, who has accepted the terms of this document and uses the services of the Website.

Administration - SwinCoin, which is the sole owner of the website on the basis of private property rights and provides organizational, financial, technical support for the maintenance and operation of the website.

Parties - Administration and Website Users.

The User Data Privacy Policy (abbreviated as "Privacy Policy") is a set of rules for processing User data and the interaction between the Parties during this process, as part of using the functions of the Website.

Acceptance is a legal action of the active form by the Party, expressing the consent of the Party with the provisions and the rules for processing User data specified in the Privacy Policy. The Parties have agreed that such an action can be expressed:
(a) by the Administration through publishing this Privacy Policy on the Website;
(b) By the User - in a manner determined by the provisions of the Privacy Policy.

General Data Protection Regulation (abbreviated - "GDPR") - General Data Protection Regulation 2016/679 of the European Parliament and the Council of the European Union of April 27, 2016, on the protection of individuals with respect to the processing of personal data and the free movement of such data, and also repealing Directive 95/46 / EC (General Data Protection Regulation).

Personal data - any factual information that allows identifying the data subject. Such information includes, but is not limited to, name, location data, online identifier or one or more factors characteristic of physical, physiological, genetic, mental, economic, cultural or social identity, including, but not limited to, IP addresses, name, email, API tokens, billing information, HTTP response (status) code.

Website - an Internet resource with the domain name, under control and owned by the Administration based on private property rights.

  1. General conditions
    1. This Privacy Policy describes the procedure for the processing and protection by the Administration of personal data about Users that can be obtained by the Administration when the User accesses the services provided on the Website.
    2. This Privacy Policy, as well as in our algorithms for interacting with Users, takes into account the requirements of the General Data Protection Regulation and the Federal Law "On Personal Data".
    3. The Administration provides its services exclusively to persons who have reached the age of 18, who can acquire civil rights and independently exercise them through their actions.
    4. The Administration simultaneously has two legal statuses provided for by the Rules for the protection of personal data:
      (a) Data Controller
      (b) Data Processor
    5. In terms of relations with the Users of the Website, the Administration has the legal status of Data Controller.
    6. In terms of relations between the User of the Website and third parties where the functions of the Website are involved, the Administration has a legal status of Data Processor
    7. The purpose of this Privacy Policy is to ensure adequate protection of information about Users, including their personal data, from unauthorized access and disclosure.
    8. Relations related to the collection, storage, distribution and protection of information provided by the User are governed by this Privacy Policy. The Administration puts a strong focus on data protection.
    9. The Administration can inform Users about how it uses the information received on the Website.
    10. Users who intend to use the Website for the first time, including in a test format, must first acknowledge the provisions of the Privacy Policy.
    11. Users who access the Website after Privacy Policy acquires legal force have to acknowledge its current provisions on the
    12. Users, including those mentioned in clauses 1.10., 1.11., who have read and agreed to with the provisions of this Privacy Policy, express their full agreement with the terms of this Privacy Policy and grant the Administration the right to use and process personal data about them for the purposes of the Website.
    13. Not fulfilling the obligation of clause 1.12. of the Privacy Policy, the User is considered not to have accepted the terms of the Privacy Policy. In this case, the User is not allowed to use the Website, and he is deprived of the opportunity to use the functions of the Website.
    14. In case of disagreement with the provisions of this document (in part or whole), the disagreeing person has no right to use its Websites. In this case, this Party faces consequences provided for by clause 1.13 of the Privacy Policy.
  2. Principles of processing personal data of Website Users.
    1. Personal data is legally, fairly and transparently processed by the Administration in relation to the User.
    2. The processing of the User's personal data is carried out only for the purposes for which this data is collected.
    3. The User's personal data must correspond to, relate to and be limited to the purpose of using the Website for which such data is processed.
    4. The User's personal data used by the Administration shall be accurate and up-to-date. Outdated and inaccurate entries are edited or deleted by the Administration.
    5. The Administration conducts regular checks in order to clean up the database in an orderly manner. The Administration stores information of Users for a certain period, if this is justified by commercial or legal purposes.
    6. Personal data is processed by the Administration to ensure adequate protection of personal data, including protection from unauthorized or illegal processing, as well as from accidental loss, destruction or damage using special technical or organizational measures.
  3. The procedure for using the data provided by the Users of the Website
    1. To provide the User with services on the Website, the Administration collects two types of data: personal and non-personal.
      1. Personal information includes the information that allows you to find out the identity of the User, contact him or determine his location (IP). In case of refusal to provide his personal information, the User has access to most of the website.
      2. Personal information is collected by the Administration when the following operations are made on the Website:
        - Acquisition of SwinCoin;
        - Subscribing to promotional mail and newsletters.
      3. The Administration uses the personal information of Users to provide services, send promotions and offers, as well as to improve the Users' experience on the Website.
      4. Non-personal information contains information that doesn't help identify a specific individual.
  4. Purposes of collecting, processing and storing data provided by the Users of the Website
    1. The processing of personal data about the User is carried out by the Administration in order to:
      - identify the User as part of the relationship between the Administration and the User;
      - provide the User with a number of services available on the Website;
      - run statistical and other studies based on anonymized data.
    2. In the event that the Administration acts as a Data Processor, data about third parties with whom the User interacts as part of his activities is collected by the Administration solely for the purpose of storage.
  5. Rights of Users providing their Personal data for processing
    1. The User has the right to:
      1. Request from the Administration the information about:
        (a) the purposes of processing the User's data by the Administration;
        (b) persons to whom personal data were or will be disclosed, in particular recipients in countries outside the European Union or international organizations;
        (c) the anticipated period for which the personal data will be stored, or, if this is not possible, the criteria used to determine this period;
      2. Request from the Administration information identifying the categories of personal data;
      3. Request the controller to correct or delete personal data or to restrict the processing of personal data in relation to the data subject or to object to such processing;
  6. Conditions for the processing of personal information provided by the User and its transfer to third parties
    1. The Administration takes all necessary measures to protect personal data about the User from unauthorized access, modification, disclosure or destruction.
    2. The Administration provides access to personal data about the User only to the persons who need this information to ensure the functioning of the Website in order to provide services to the User.
    3. In order to provide services to the User, the Administration has the right to submit User's personal data to third parties to provide the required services. In this case, the data is transferred confidentially in accordance with all obligations to ensure the security of personal information.
    4. The Administration applies the necessary, from a commercial point of view, measures to prevent the collection, modification or destruction of information by third parties received by the Administration on the Website.
    5. The measures specified in clause 6.5. include network traffic control to identify unauthorized attempts to download or modify information, as well as, in certain circumstances, encryption of confidential information using Secure Sockets Layer (SSL) or other similar technologies. The Website also exerts control to prevent any illegal activity, or activity that may subject the Administration to legal liability or cause damage to it.
    6. The Administration assumes obligations to ensure the security of the Website, as well as to constantly make sure the Website operates within legal boundaries so that the services provided through the Website remain available to all Users.
    7. Although the Administration takes all necessary, from a commercial point of view, measures to prevent unauthorized third parties from obtaining personal information of Users available to the Administration through the Website, illegal interception or capturing of information by third parties is still possible.
    8. In the event of a leak/hacking/compromise of personal data, the Administration must alert the relevant authorities no later than 72 hours after the Administration becomes aware of such a leak/hacking/compromise.
  7. Terms of use of the Website
    1. The User utilizing the Website confirms that he:
      1. possesses all the necessary rights that allow him to acquire civil rights and independently exercise them, as well as the ability to assume civil obligations, independently fulfill them and bear responsibility if they are not fulfilled;
      2. provides reliable data about himself in the amount necessary to use the services of the Website. Mandatory fields for the further provision of the Website's services are marked with the symbol "*", all other information is provided by the user at his discretion.
      3. is familiar with the terms of this Privacy Policy, expresses his consent to it and assumes the rights and obligations specified in it.
      4. The Administration does not check the accuracy of the information received (collected) about the Users, except for cases when such verification is necessary in order to fulfill obligations to the User, as well as in other cases not provided for by the Privacy Policy.
      5. agrees to receive periodic e-mails about updates to the services provided through the Website.
    2. The User has the right to receive his personal data, which the User has provided to the Administration, and also has the right to transfer this data to other persons, without interference from the Administration who received such data.
    3. The user has the right to object to certain ways of processing his personal data - direct marketing, processing in order to protect legitimate interests or perform any task in the public interest/exercise of power, as well as data processing for research or statistical purposes.
    4. The Administration has the right to provide links to websites and materials of third parties. These links to third-party websites and materials are provided solely for informational purposes.
  8. Under this Privacy Policy, "personal data about the User" means:
    1. The data provided by the User independently in the process of using the Website, including, but not limited to: name, last name, contact phone number and/or e-mail address, IP-address, MAC-address, etc.
    2. Data automatically submitted to the Website using the software installed on the User's device, including the IP address, cookies data, information about the User's browser (or other software used to access the Website is accessed), access time, the address of the requested webpage.
    3. The Administration uses non-personal information through the use of cookies, non-personal information through the use of cookies or through the collection of the data exchange traffic, produced in order to optimize the use of the Website, the date and time of visiting the Website, etc. Examples of traffic flow include:
      - name of the domain or URL used to access the Internet;
      - Internet Protocol (IP) address;
      - type of web browser used;
      - date and time of visiting the website, etc.
    4. Other information about the User, the collection and/or provision of which is determined by the terms of use of the Website.
  9. Modification and removal of personal data
    1. The User can, at any time, change (update) the personal information (or a part of it) provided by him, as well as the parameters of its confidentiality, by sending this information to the Administration's e-mail.
    2. The User can, at any time, delete the personal information provided by him or its part, in order to avoid its distribution or submission to third parties.
    3. The Administration has the right to delete the personal data about the User if they are no longer needed for the purposes for which they were collected, or if there are no other grounds for their storage.
  10. Changes to the Privacy Policy.
    1. The Administration has the right to make changes to this Privacy Policy. When making changes to the current edition, the date of the last update is indicated. The new edition of the Privacy Policy comes into force from the moment it is published on the Website, unless otherwise provided by the new edition of the Privacy Policy. The current version of the Privacy Policy can be found at:
  11. Contacts
    1. Please submit all suggestions or issues regarding this Privacy Policy to the Administration at: