PRIVACY POLICY (GDPR)

The Company has established the following privacy policy (hereinafter referred to as the "Privacy Policy") regarding the handling of customer information when using the various services and websites provided by the Company (hereinafter collectively referred to as the "Services"). The Company has established the following privacy policy (hereinafter referred to as the "Privacy Policy") with respect to the handling of customer information when using the various services and websites provided by the Company (hereinafter collectively referred to as the "Services"). The Company has established the following privacy policy (hereinafter referred to as the "Privacy Policy") regarding the handling of customer information.

Article 1 Customer Information and Personal Data

  1. Customer Information means the information of customers who use the Service.
  2. PERSONAL DATA IS ANY INFORMATION ABOUT YOU THAT RELATES TO AN IDENTIFIED OR IDENTIFIABLE NATURAL PERSON, SUCH AS NAME, E-MAIL ADDRESS, ORGANIZATION NAME, LOCATION, TELEPHONE NUMBER, SOCIAL NETWORK SERVICE ACCOUNT, IP ADDRESS, COOKIE IDENTIFIER, ETC.

Article 2: Consent to Privacy Policy

By indicating your acceptance of this Privacy Policy, you agree to be bound by it. You may withdraw your consent to this Privacy Policy at any time.
However, if you withdraw your consent, you will not be able to use the Services (or any features) that require the use of information that we have obtained based on your consent.
In addition, customers under the age of 15 must have the consent of their parents or guardians to use the Service, or must obtain permission from their parents or guardians before using the Service.

Article 3 Information Obtained by the Company in the Service

We may obtain the following customer information from you for the Service. If you do not provide this information, you may not be able to use all or part of the Service.

  • (1) Information obtained directly from the customer's registration for the Service or changes to the registered contents, or through inquiries or communications from the customer
    • identity
    • Email Address
    • Company Name
    • Phone number
    • Information related to your contract
    • Information from inquiries to customer support
    • Customer feedback information, such as ratings or complaints
  • (2) Information automatically obtained through the customer's use of the Service
    • location information (as used by location-based services, e.g. GPS position)
    • Information on service usage (e.g., information on behavior settings, number of file uploads, device orientation at time of crash, etc.)
    • Date and time of access to this service
    • The type of device application and browser used to view the Service and the pages viewed
      (including websites of third party services that you used prior to using the Service)
    • INFORMATION ON THE DEVICE USED TO ACCESS THE SERVICE, HARDWARE MODEL, IP ADDRESS, MAC ADDRESS OR OTHER UNIQUE IDENTIFIER OF THE DEVICE, OPERATING SYSTEM AND ITS VERSION, LANGUAGE OF CHOICE, ADVERTISING IDENTIFIER, SERIAL NUMBER, DEVICE OPERATING INFORMATION, AND MOBILE NETWORK INFORMATION
  • (3) Information obtained through services operated by third parties
    If you allow us to obtain your information through services operated by third parties, we may obtain your information. In such cases, we may match the information we obtain from you with the information we obtain from the third party in order to improve the Service and to provide you with advertisements that match your interests.

Article 4 Purpose of Use of Customer Information

We use acquired customer information for the following purposes

  • (1) To provide, maintain, protect, and improve the Service, such as by accepting registrations for the Service, verifying the identity of users, and calculating usage fees.
  • (2) For notification of information regarding the contents of this service, updates, events and campaigns, and changes in terms and conditions, etc.
  • (3) To provide information on this service and to respond to inquiries, etc.
  • (4) To respond to acts that violate the Company's terms of service or other regulations regarding this service.
  • (5) To compile statistical data on the use of this service
  • (6) For planning, drafting or implementation of future Services
  • (7) To send prizes, etc. to customers who have won prizes in campaigns, etc.
  • (8) To analyze registration information and usage conditions in order to make the contents and advertisements provided by third parties that you see when using the Service more convenient for you.
  • (9) To understand the delivery status of advertisements, measure the effectiveness of advertisements, and display behaviorally targeted advertisements
  • (10) To provide a portion of the information to ad-serving companies with which we are affiliated (hereinafter simply referred to as "ad-serving companies"). (The information will be used for the advertising service of the operator and will not contain any information that could identify a specific individual.)
  • (11) To distribute or display advertisements of the Company or third parties

Article 5 Provision of Information to Third Parties

  1. We may provide personal data among the acquired customer information to third parties in the following cases
    • (1) When the customer agrees
    • (2) If we have reasonable grounds to believe that you have violated our terms and conditions and that we must disclose your personal data to protect our rights, property, or services.
    • (3) When it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the individual.
    • (4) Cases in which it is necessary to cooperate with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and in which obtaining the customer's consent may impede the execution of such affairs.
    • (5) When our business, including the provision of personal data, is succeeded due to a merger, corporate separation, transfer of business, or other reasons
    • (6) When provided to business partners in order to provide services requested by customers, such as payment processing, data analysis, customer service, etc.
    • (7) When providing functions or services on our behalf to third parties in order to provide various functions or services through the Service.
    • (8) When we provide the information to an advertising distributor in order to deliver advertisements that match the interests of our customers.
    • (9) When permitted by other laws and regulations
  1. We require third parties to whom we provide personal data to comply with the European General Data Protection Regulation ("GDPR") The Company obliges third parties to whom it provides personal data to comply with the European General Data Protection Regulation ("GDPR") and related laws and regulations, and to handle customer information in a manner that takes into consideration the privacy of customers. Please contact the third party to which you provide your personal information for details on the handling of your personal information by the third party to which you provide your personal information.
    In addition, it may be necessary to transfer personal data to countries outside the EU. When we perform such transfers, we will ensure that the data to be transferred is protected at an appropriate level.

Article 6. Joint Use of Acquired Personal Data

When a business partner is required to work with us in providing this service to customers, we may share the customer's personal data with that business partner. In such cases, we will disclose to you the purpose of the joint use, the scope of the information, the scope of the business partner, and the responsible party before the joint use.

Article 7 Deposit of Acquired Personal Data

  1. We may outsource all or part of the handling of personal data to subcontractors to the extent necessary to achieve the purpose of use. In such cases, the Company will thoroughly examine the eligibility of the subcontractor, stipulate confidentiality obligations in the contract, and establish a system to ensure that the information is properly managed.
  2. We outsource the handling of personal data for some services by using the following services.

Article 8 Deletion of Customer Information

We may retain customer information while you are in a contractual relationship with us and thereafter, but we will not keep more than necessary. When the purpose of collecting and processing customer information has been achieved, we will delete such customer information without delay.
The length of time we retain your customer information depends on the type of customer information and the purpose of the processing.

Article 9 Records of Our Processing of Customer Information

WHEN WE PROCESS CUSTOMER INFORMATION, WE WILL HANDLE RECORDS OF THE PROCESSING OF CUSTOMER INFORMATION IN ACCORDANCE WITH THE OBLIGATIONS SET FORTH IN THE GDPR. WE WILL REFLECT IN THESE RECORDS ALL INFORMATION NECESSARY TO COMPLY WITH THE GDPR AND TO COOPERATE WITH SUPERVISORY AUTHORITIES IN ACCORDANCE WITH THE GDPR.

Article 10 Security Measures

When we process customer information, we do so with appropriate technical and organizational measures to ensure appropriate security.

Article 11 Notification of Infringement of Customer Information to Competent Supervisory Authorities

In the event of a security breach that results in the accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access of customer information subject to transfer, storage, or other processing, we have systems and measures in place to promptly detect and assess the nature of the breach. Depending on the results of the evaluation, we will make the necessary notifications to the supervisory authorities and contact the affected customers.

Article 12 Rights Regarding Customer Information

CUSTOMERS IN THE EU HAVE THE FOLLOWING RIGHTS UNDER THE GDPR WITH RESPECT TO OUR HANDLING OF CUSTOMER INFORMATION. TO EXERCISE ANY OF THESE RIGHTS, PLEASE CONTACT THE CONTACT POINT SET FORTH IN ARTICLE 15.

  • (1) Explanation and copy of customer information
    Customers have the right to request an explanation of the customer information held by the Company and an explanation of how such information is used by the Company.
    In addition, if the Company acquires Customer Information based on consent or because it is necessary to provide services requested by the Customer, the Customer has the right to receive a copy of such information that the Company has acquired with respect to the Customer.
  • (2) Correction
    If you believe that any information we hold about you is inaccurate, you have the right to request that we correct your information.
  • 3) Deletion
    You have the right to request deletion of your own customer information.
  • (4) Restrictions on Processing
    You have the right to prohibit or restrict our processing of your information.
  • (5) Right to portability
    You have the right to have us transfer your information directly to third parties to the extent technically feasible.
  • 6) Objections and Complaints
    If you believe that we are not complying with our obligations under this Privacy Policy or the GDPR, you have the right to file a complaint with the EU data protection authorities.

Article 13 Cookies

  1. Through the Service, we and our ad-serving vendors may send cookies to your browser and use that technology.
  2. You can disable or refuse to accept cookies by changing your browser settings. Please note that some parts of the Service may not function properly if you disable or reject cookies. Please see below for instructions on how to set your browser.
  1. If you have set your browser to accept cookies, an ad-serving company may obtain cookie information such as your browsing history when you use the Service, and our advertisements may be delivered to you on the ad-serving company's ad space.
  2. Ad-serving providers may use cookies, access data, our identifiers, and your demographic information to deliver advertisements that are tailored to your interests and preferences.
  3. Your cookie information obtained by the ad-serving provider will be handled in accordance with the ad-serving provider's privacy policy.

Article 14 Links

This Privacy Policy does not apply to websites linked to from the Service that are provided by entities other than the Company, and the Company assumes no obligation or responsibility for the acquisition of customer information by such entities. We assume no obligation or responsibility for the acquisition of customer information by such business entities.

Article 15 Contact for Inquiries

If you have any comments or questions regarding this Privacy Policy, or any other inquiries regarding the handling of customer information, or requests in accordance with Article 12, please contact us using this form.

Article 16 Revision

The Company may revise this Privacy Policy at any time, and you agree to be bound by such revisions. Unless otherwise specified by the Company, any changes to this Privacy Policy shall be announced to you from time to time by posting on the Service, and shall become effective upon such posting.

... and upwards

January 4, 2021 Revised

For inquiries regarding personal information and specified personal information, please contact:
SWAPSSS S.A.S. (Co., Ltd.)
15 Boulevard Daviers 49000 Angers France
 Tel:+33(0)9 77 71 08 64
E-mail: privacy@swapsss.com