Swavy Marketing FZ LLC Privacy Policy
1. Introduction
Swavy Marketing FZ LLC ("Swavy," "we," "us," or "our") is committed to protecting the privacy of our users ("you" or "your"). This Privacy Policy outlines our practices regarding the collection, use, and disclosure of your information when you use our online creator marketplace platform (the "Service"). By accessing or using the Service, you agree to the terms of this Privacy Policy.
2. Information We Collect
2.1 Personal Information
When you register for an account, we may collect the following personal information:
- Name
- Email address
- Telephone number
- Payment information (recipient bank details)
- Profile information (e.g., profile picture, bio, social media links)
We collect and process your personal data only with your explicit consent, unless the processing is required to fulfill a contractual obligation or comply with legal obligations, in accordance with the Saudi Personal Data Protection Law (PDPL), the UAE Personal Data Protection Law and the General Data Protection Regulation.
2.2 Non-Personal Information
We may collect non-personal information about your use of the Service, including:
- IP address
- Browser type and version
- Device information
- Operating system
- Referring URLs
- Pages viewed and links clicked
- Usage data (e.g., time spent on the platform, interactions with features)
2.3 Cookies and Tracking Technologies
We use cookies and similar tracking technologies to collect information about your interactions with the Service. You can control the use of cookies through your browser settings and through our cookie consent system.
3. How We Use Your Information
3.1 To Provide and Improve the Service
We process your data for the following purposes:
- To provide and maintain our Service (Legal Basis: Contract)
- To monitor the usage of our Service (Legal Basis: Consent, where applicable)
- To analyze campaign performance and behavior (Legal Basis: Consent, where applicable)
- To communicate with you about platform updates (Legal Basis: Consent - optional)
- To comply with legal obligations in the jurisdictions where we operate
3.2 Marketing and Communications
With your consent, we may use your personal information to send you promotional materials and updates about our products and services. You can opt out of these communications at any time.
3.3 Compliance and Legal Obligations
We may use your information to comply with applicable laws, regulations, and legal processes, and to protect our rights and interests.
4. How We Share Your Information
4.1 With Service Providers
We may share your information with third-party service providers who assist us in operating the Service, such as payment processors, hosting providers, and email service providers. These service providers are contractually obligated to protect your information and use it only for the purposes specified by Swavy.
4.2 With Other Users
When you participate in the Service (e.g., by applying to a campaign or posting a campaign), your profile information and any content you submit may be visible to other users.
4.3 In Connection with Business Transactions
In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of the transaction. We will notify you of any such change in ownership or control of your personal information.
4.4 For Legal and Safety Reasons
We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend our rights or property
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of users or the public
4.5 Third-Party Data Sharing
We may share your data with the following service providers:
- Meta Platforms – for campaign tracking and performance measurement
- TikTok (Bytedance) – for creator attribution and traffic analysis
- Snap Inc. – for marketing tracking
- Google (Analytics) – for usage analytics and performance reporting
- PostHog – for behavior analysis and product improvement
- Supabase (EU) – hosting platform
- Vercel (EU) – frontend deployment infrastructure
These partners may store or process your data outside of Saudi Arabia, subject to appropriate safeguards.
All third-party providers are bound by strict confidentiality and security obligations. Data is only shared after obtaining your explicit consent during signup or via cookie banner.
4.5 International transfers
Swavy transfers your data outside the Kingdom of Saudi Arabia (KSA), including to the European Union, for the purposes of providing our services. These transfers are necessary for the performance of the services you request and are protected with adequate safeguards in line with Article 29 of the Saudi PDPL.
5. Data Security
We implement reasonable security measures to protect your information from unauthorized access, use, or disclosure. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee the absolute security of your information.
6. Data Retention
We retain your operational data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer or shorter retention period is required or permitted by law. When we no longer need your personal information, we will securely delete or anonymize it. We retain your account data until deletion, then erased within 30 days, or 3 years of inactivity. We retain tracking data for 13 months.
7. Your Rights and Choices
Under Saudi Arabia and UAE's PDPLs, you have the right to be informed, provide explicit consent for data processing, and withdraw consent at any time.
7.1 Access and Correction
You have the right to access and update your personal information. You can review and edit your account information by logging into your account settings.
7.2 Deletion and Restriction
You have the right to request the deletion or restriction of your personal information. To exercise these rights, please contact us at support@swavy.app. Please note that certain information may be retained for legal or legitimate business purposes.
7.3 Objection and Withdrawal of Consent
You have the right to object to the processing of your personal information and to withdraw your consent at any time. To exercise these rights, please contact us at support@swavy.app.
7.4 Data Portability
You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format. To exercise this right, please contact us at support@swavy.app.
8. International Data Transfers
Your information, including Personal Data, may be transferred to and stored in countries outside the Kingdom of Saudi Arabia (KSA), including the European Union and the United States. These transfers are necessary for us to provide the services you request and are governed by appropriate safeguards, including encryption, access controls, and contractual protections.
In accordance with Article 29 of the Saudi PDPL, such transfers are allowed when they are necessary for the performance of a service and do not adversely affect your privacy rights.
9. Children’s Privacy
The Service is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on the platform. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
11. Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us at support@swavy.app.
For any questions or concerns regarding your personal data, you can contact our data protection officer (DPO) at support@swavy.app.
Swavy monitors developments related to the Saudi Personal Data Protection Law (PDPL) and will register with the Saudi Data & Artificial Intelligence Authority (SDAIA) when required.
