Terms
By registering and opening an account to use SWAPITWAY Services, you have unconditionally agreed to and accept the terms and conditions stated hereunder: You undertake not to use SWAPITWAY products and services to facilitate any illegal activities. The information contained on this website does not constitute accounting, legal, financial, consulting, investment or other professional advice. You bear all the risks from any decision to use SWAPITWAY and SWAPITWAY shall not be liable for any loss suffered. Your account may be terminated if we discover that you have provided us with false or misleading information, or refuse to provide correct information about your true identity. You agree and consent to receive correspondence from SWAPITWAY via email, SMS, app notifications, social media, letters or any other media we use. You are responsible for maintaining adequate security and control of any and all IDs, passwords, personal identification numbers (PINs), or any other codes or credentials that you use to access the services. You are not allowed to sell, borrow, share or otherwise make available your account or any detail necessary to access your account to people or entities other than yourself. Your account shall not contain misleading or fraudulent information, including, but not limited to, having a non-personal phone number, creating fake reputation information for your account, faking your country of origin or providing fraudulent identification documents. We may at any time require you to complete our ID verification process and may also require you to submit additional identification documents to us if we deem it necessary. Failing to complete ID verification will be considered a violation of these Terms. SWAPITWAY may change these Terms of Use at any time for any reason without notice. SWAPITWAY may suspend your account at any time for any reason. Acceptance and Change of Terms If you do not agree with any of these Terms of Service please do not use the SWAPITWAY website, app and its services. By using this site or any of SWAPITWAY services, you will be deemed to have irrevocably agreed to these terms and conditions. Please note that these Terms of Service may be revised and reissued without notice at any time. You should visit this page regularly, and before engaging in any trades in particular, to review the current Terms of Service, since your continued use of the site will be deemed as an irrevocable acceptance of any revisions. Notwithstanding the above, we will strive to notify you of changes to these Terms of Service which significantly affect your rights and obligations. Such notices shall be sent to the email address you provided as part of your account settings and it is your responsibility to keep your contact information up to date. Transactions The Bitcoin, Ethereum and Litecoin network is responsible for confirming Bitcoin, Ethereum and Litecoin transactions. CARDTONIC is not liable for any loss due to, but not limited to, errors in the protocol, delays or any other breakdown relating to the Bitcoin network, Ethereum network and or Litecoin network. You acknowledge that SWAPITWAY cannot confirm, cancel or reverse coin transactions. You expressly agree that SWAPITWAY is not liable for any errors, loss or omissions due to sending Bitcoin to or receiving Bitcoin from incorrect wallet addresses, e-mail addresses, entering incorrect transaction amounts, or any other information related to coin transactions by using the service. Please ensure that you use the correct coin addresses, e-mail addresses, transaction amounts when transacting. By using SWAPITWAY, you accept the risk that transactions may be delayed and you agree not to hold SWAPITWAY liable for any damages or loss due to delays. Trade orders placed on SWAPITWAY are binding and cannot be cancelled or reversed. You acknowledge that the gift cards you trade on SWAPITWAY belong to you and was purchased through proper channels without violating any law. This service is provided without warranty of any kind and SWAPITWAY does not guarantee that the site will be available 100% of the time. You acknowledge and accept that the website may become unavailable from time to time due to various circumstances and that SWAPITWAY will not be liable for any losses due to the system or service becoming unavailable. SWAPITWAY cannot and does not guarantee the value of any traded item and has no obligation to buy back such traded items at any time. It is the customer's responsibility to pay for all transaction taxes. Investigations SWAPITWAY reserves the right to investigate suspected violations of these Terms of Service, including without limitation any violation arising from any submission, posting or e-mails you make or send to any forum on the site. SWAPITWAY may seek to gather information from the user who is suspected of violating these Terms of Service, and from any other user. SWAPITWAY may suspend any users whose conduct or postings are under investigation and may remove such material from its servers as it deems appropriate and without notice. Account Monitoring, Suspension and Termination Upon probable cause to believe that you have acted in violation of these Terms of Service or: That any content or material submitted or shared by you in or through the services violates these Terms of Service or the intellectual property rights, other property rights or the right to privacy of any third party. We have reason to believe that your use of the services is in violation of any applicable law or regulation, or that you are using the services in a fraudulent manner or otherwise contrary to the purpose of this Agreement. We have reason to believe that you have supplied false, misleading or deceptive information in connection with your registration, identity verification, transactions or any other use of the services, either to us or to another user. You have not responded to our inquiries or supplied the information requested by us within a reasonable period of time We are required to do so under any applicable law, regulation or an order issued by an authority If we determine that you have at any previous point in time violated this Agreement or any other agreement that you have entered into with us, Upon the occurrence of ANY of the above, SWAPITWAY shall immediately close, suspend or limit your account. Valid payment details must be provided through authorized SWAPITWAY web, app, or specified trading system. It is a violation of these Terms of Service to provide payment details through other unauthorized channels. Buyers must be able to, upon our request, provide adequate proof of payment for up to 180 days after trades has been completed. PROHIBITED ACTIVITIES SWAPITWAY strives to attain and maintain the highest security culture and compliance standards to government laws and regulations as well as protection of our customers. Engaging in any of the prohibited activities specified below may give rise to prosecution by law enforcement agencies. The following acts are prohibited on SWAPITWAY web, mobile, app or other platforms. Gathering, stealing or engaging in unauthorized collection of information about users. Changing, amplifying or modifying any part of the site or the services for any purpose whatsoever. Disguising identity or user credentials, use of another user's credentials in engaging with SWAPITWAY. Alter-engineering, reverse-engineering or otherwise tampering with SWAPITWAY platform in order to find limitations or vulnerabilities. Covert engineering of products/services for unauthorized purposes. GRIEVANCE POLICY SWAPITWAY believes in providing excellent service and strives to be sincere and transparent in its approach to customer service. Your confidence in us is of paramount importance to us and we would never place our personal growth before your interest. This Policy aims to minimize instances of customer complaints, grievances, and disputes through a channelized approach of review and redress. Your feedback will help us in identifying shortcomings in our product features and service delivery. Your satisfaction is our main objective in our quest to build a healthy customer relationship and deliver excellent service. SWAPITWAY has developed a procedure for the prompt attention to the grievances of its customers with respect to various issues by setting up a “customer support” and “a dispute resolution mechanism”. The following are the foundational principles of this policy: Transparency; Prompt, courteous and timeous response to all queries, enquiries, and complaints; and Constantly developing new and smarter mechanisms to receive and address customer grievances. The details of the dispute resolution mechanism are placed in the domain of public knowledge. A dispute may occur as a result of several reasons. It may be because of the difference in the service expected and the service delivered. A dispute may also arise as a result of technical or non-technical errors in the system or at times due to human inadvertence or error. SWAPITWAY provides a user-friendly platform to all its customers to file a complaint/ share feedback if they are disappointed by the services rendered. Customers can give their complaint/ feedback in sending an email to (INSERT CUSTOMER SERVICE EMAIL HERE) If the user’s grievance is not resolved within the stipulated time frame, or if the user is not completely satisfied with the solution provided by SWAPITWAY, then they can approach our dispute resolution system with their complaint or explore other legal avenues available for dispute resolution. To make SWAPITWAY dispute resolution system more meaningful and effective, a structured system has been put in place. This system will ensure that the complaints are redressed seamlessly and well within the stipulated time frame. Expertise of staff in handling complaints Our staff undergo regular training to ensure that consumers' queries and grievances are handled properly. They are trained to work in a manner that enhances consumer trust and confidence in us. Our objective to achieve maximum customer satisfaction can be witnessed in both the operations as well as in customer communications. We analyze consumer queries and complaints and ensure the removal of such complaints from the root. This helps in improving the overall quality of the service levels gradually. Introduction to our Dispute Resolution System The users’ experience is our focus and this is why we devote ourselves to listen to our users and take their concerns seriously. We positively analyze and scrutinize how you would feel from the time you make requests for our services till the time you’re done to evolve and enhance our services. We ensure a simply incredible and user-friendly experience to all our customers and in case of any complaint or concern, we do everything we can to fix them
Privacy
This Privacy policy between SWAPITWAY TECHNOLOGIES (hereinafter referred to as SWAPITWAY) and you, constitutes our commitment to your privacy on our website, apps, social media platforms, administrative records and premises. 1.0 Your Privacy Rights This Privacy Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your personal information. It applies to the SWAPITWAY website, apps, platforms and all database applications, services, tools and physical contact with us regardless of how you access or use them. If you have created a username, identification code, password or any other piece of information as part of our access security measures, you must treat such information as confidential, and you must not disclose it to any third party. We reserve the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our opinion you have failed to comply with any of the provisions of these Conditions. If you know or suspect that anyone other than you know your security details, you must promptly notify us at (INSERT SWAPITWAY EMAIL HERE). 2.0 Consent You accept this Privacy Policy when you give consent upon access to our platforms, or use our services, content, features, technologies or functions offered on our website, apps, digital platforms or visit any of our offices for official or non-official purposes (collectively “SWAPITWAY services”). This Policy governs the use of SWAPITWAY services and intervention projects by our users and stakeholders unless otherwise agreed through written contract. We may amend this Privacy Policy at any time by posting a revised version on our website, apps, platforms, or placing such notice at conspicuous points at our office facilities. The revised version will be effective 7-days after publication. 3.0 Your Personal Information When you use SWAPITWAY Services, we may collect information sent to us by your computer, mobile phone or other electronic access device. The automatically collected information includes but not limited to- data about the pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, standard web log data, still and moving images. We may also collect information you provide us including but not limited to - information on web forms, survey responses, account update information, email, phone number, organization you represent, official position, correspondence with SWAPITWAY support services and telecommunication with SWAPITWAY. We may also collect information about your transactions, enquiries and your activities on our platforms or service channels. We may also use information provided by third parties like social media sites. Information about you provided by other sites are not controlled by SWAPITWAY and we are therefore not liable for how they use it. 4.0 What we do with your personal information The purpose of our collecting your personal information is to give you efficient, enjoyable and secure service. We may use your information to: Provide SWAPITWAY services and support; Process applications and send notices about your transactions to requisite parties; Verify your identity; Resolve disputes, collect fees, and troubleshoot problems; Manage risk, detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities; Detect, prevent or remediate violation of Laws, Regulations, Standards, Guidelines and Frameworks; Improve SWAPITWAY Services by implementing aggregate customer or user preferences; Measure the performance of the CARDTONIC's Services and improve content, technology and layout; Track information breach and remediate such identified breaches; Manage and protect our information technology and physical infrastructure; Contact you at any time through your provided telephone number, email address or other contact details. 5.0 Cookies Cookies are small files placed on your computer’s hard drive that enables the website to identify your computer as you view different pages. Cookies allow websites and applications to store your preferences in order to present contents, options or functions that are specific to you. Like most interactive websites, our website uses cookies to enable the tracking of your activity for the duration of a session. Our website uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the browser. Session cookies do not collect information from the user’s computer. They will typically store information in the form of a session identification that does not personally identify the user. 6.0 How we protect your personal information We store and process your personal information on our computers in Nigeria. Where we need to transfer your data to another country, such country must have an adequate data protection law. We will seek your consent where we need to send your data to a country without an adequate data protection law. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. 7.0 How We Share your information within SWAPITWAY and other users During your interaction with any of our platforms or premises, we may provide Ministries, Departments, Agencies (MDAs), other organs of government, private sector operators performing government functions, with information such as your name, contact details, or other details you provide us for the purpose of performing their statutory mandate to you or third parties. We work with third parties, banks, financial institutions and corporate bodies to perform SWAPITWAY services and implement its mandate. In doing so, a third party may share information about you with us, such as your email address or mobile phone number. You accept that your pictures and testimonials on all social media platforms about SWAPITWAY can be used for limited promotional purposes by us. This does not include your trademarked or copyrighted materials. From time to time we may send you relevant information such as news items, enforcement notice, statutorily mandated notices and other informative notices to help SWAPITWAY serve you better. We may also share your personal information in compliance with National or international laws; crime prevention and risk management agencies and service providers. 8.0 Security We promise to and will always hold your information securely. To prevent unauthorized access to your information, we have implemented strong controls and security safeguards at the technical and operational levels. You should see the padlock symbol in your URL address bar once you are successfully logged into the platform. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your device and the connecting server. Any data transmitted during the session will be encrypted before transmission and decrypted at the receiving end. This is to ensure that data cannot be read during transmission. SWAPITWAY has also taken measures to comply with global Information Security Management Systems (ISMS) we therefore have put in place digital and physical security measures to limit or eliminate possibilities of data privacy breach incidents. 9.0 Data Confidentiality Rights Your information is regarded as confidential and will not be divulged to any third party except under legal and/or regulatory conditions. You have the right to request sight of, and copies of any and all information we keep on you. While SWAPITWAY is responsible for safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes, but is not limited to, adopting and enforcing appropriate security measures such as non-sharing of passwords and other platform login details, adherence with physical security protocols on our platforms, dealing with only authorized officers of SWAPITWAY. 10.0 Links to Other Websites and Premises Certain transaction processing channels may require links to other websites other than ours. Please note that SWAPITWAY is not responsible and has no control over websites outside its domain. We do not monitor or review the content of other party’s websites which are linked from our website or media platforms. Opinions expressed or materials appearing on such websites are not necessarily shared or endorsed by us, and SWAPITWAY should not be regarded as the publisher of such opinions or materials. Please be aware that we are not responsible for the privacy practices, or content of these sites. We encourage our users to be aware of when they leave our site and to read the privacy statements of these sites. You should evaluate the security and trustworthiness of any other site connected to this site or accessed through this site yourself, before disclosing any personal information to them. SWAPITWAY will not accept any responsibility for any loss or damage in whatever manner, howsoever caused, resulting from your disclosure to third parties of personal information. 11.0 Governing Law This Privacy Policy is made pursuant to and in compliance with the Nigeria Data Protection Regulation (2019) and other relevant Nigerian laws, regulations or international conventions applicable to Nigeria. Where any provision of this Policy is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention. COOKIES POLICY Cookies are small text files which are transferred from our websites, apps, platforms or portals and stored on your device. We use cookies to help us provide you with a personalized service, and to help make our websites or portals better for you. Our cookies may be session cookies (temporary cookies that identify and track users within our websites or portals which are deleted when you close your browser or leave your session) or persistent cookies (cookies which enable our websites or portals to “remember” who you are and to remember your preferences within our websites or portals and which will stay on your computer or device after you close your browser or leave your session We use the following different types of cookies: Essential cookies These are cookies which are needed for our websites or portals to function properly, for example, these cookies allow you to access secure areas of our website/portal. Performance cookies. These cookies collect information about how visitors and users use our websites and portals. These cookies don’t collect information that identifies a visitor or user. All information these cookies collect is aggregated and therefore anonymous. We only use these cookies to improve how our website and portal. Functionality cookies. These cookies allow our websites and portals to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites. Like most interactive websites, our website uses cookies to enable the tracking of your activity for the duration of a session. Our website uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the browser. Session cookies do not collect information from the user’s computer. They will typically store information in the form of a session identification that does not personally identify the user. DATA PROTECTION POLICY SWAPITWAY Data Protection Policy refers to our commitment to treat information of employees, customers, stakeholders and other interested parties with the utmost care and confidentiality. With this policy, we ensure that we gather, store and handle data fairly, transparently and with respect towards individual rights. Scope This policy refers to all parties who provide any amount of information to us. What is covered under the Data Protection Policy? SWAPITWAY employees must follow this policy. Freelancers, consultants, partners and any other external entity are also covered. Generally, our policy refers to anyone we collaborate with or acts on our behalf and may need occasional access to data. Policy Elements As part of our operations, we need to obtain and process information. This information includes any offline or online data that makes a person identifiable such as names, addresses, usernames and passwords, digital footprints, photographs, National identity numbers, financial data etc. SWAPITWAY collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply. Our data will be: Accurate and kept up-to-date; Collected fairly and for lawful purposes only; Processed by the company within its legal and moral boundaries; Protected against any unauthorized or illegal access by internal or external parties. Our data will not be: Transferred to organizations, states or countries that do not have adequate data protection policies; Distributed to any party other than the ones agreed upon by the data’s owner (exempting legitimate requests from law enforcement authorities). In addition to ways of handling data, SWAPITWAY has direct obligations towards people to whom the data belongs. Specifically we: Let people know which of their data is collected; Inform people about how we’ll process their data; Inform people about who has access to their information; Have provisions in cases of lost, corrupted or compromised data; Allow people to request that we modify, erase, reduce or correct data contained in our databases° Actions To exercise data protection we’re committed to: Restricting and monitoring access to sensitive data; Developing transparent data collection procedures; Training employees in online privacy and security measures; Building secure networks to protect online data from cyberattacks; Establishing clear procedures for reporting privacy breaches or data misuse; Including contract clauses or communicate statements on how we handle data; Establishing data protection practices.
Policy
This Privacy policy between SWAPITWAY TECHNOLOGIES (hereinafter referred to as SWAPITWAY) and you, constitutes our commitment to your privacy on our website, apps, social media platforms, administrative records and premises. 1.0 Your Privacy Rights This Privacy Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your personal information. It applies to the SWAPITWAY website, apps, platforms and all database applications, services, tools and physical contact with us regardless of how you access or use them. If you have created a username, identification code, password or any other piece of information as part of our access security measures, you must treat such information as confidential, and you must not disclose it to any third party. We reserve the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our opinion you have failed to comply with any of the provisions of these Conditions. If you know or suspect that anyone other than you know your security details, you must promptly notify us at (INSERT SWAPITWAY EMAIL HERE). 2.0 Consent You accept this Privacy Policy when you give consent upon access to our platforms, or use our services, content, features, technologies or functions offered on our website, apps, digital platforms or visit any of our offices for official or non-official purposes (collectively “SWAPITWAY services”). This Policy governs the use of SWAPITWAY services and intervention projects by our users and stakeholders unless otherwise agreed through written contract. We may amend this Privacy Policy at any time by posting a revised version on our website, apps, platforms, or placing such notice at conspicuous points at our office facilities. The revised version will be effective 7-days after publication. 3.0 Your Personal Information When you use SWAPITWAY Services, we may collect information sent to us by your computer, mobile phone or other electronic access device. The automatically collected information includes but not limited to- data about the pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, standard web log data, still and moving images. We may also collect information you provide us including but not limited to - information on web forms, survey responses, account update information, email, phone number, organization you represent, official position, correspondence with SWAPITWAY support services and telecommunication with SWAPITWAY. We may also collect information about your transactions, enquiries and your activities on our platforms or service channels. We may also use information provided by third parties like social media sites. Information about you provided by other sites are not controlled by SWAPITWAY and we are therefore not liable for how they use it. 4.0 What we do with your personal information The purpose of our collecting your personal information is to give you efficient, enjoyable and secure service. We may use your information to: Provide SWAPITWAY services and support; Process applications and send notices about your transactions to requisite parties; Verify your identity; Resolve disputes, collect fees, and troubleshoot problems; Manage risk, detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities; Detect, prevent or remediate violation of Laws, Regulations, Standards, Guidelines and Frameworks; Improve SWAPITWAY Services by implementing aggregate customer or user preferences; Measure the performance of the CARDTONIC's Services and improve content, technology and layout; Track information breach and remediate such identified breaches; Manage and protect our information technology and physical infrastructure; Contact you at any time through your provided telephone number, email address or other contact details. 5.0 Cookies Cookies are small files placed on your computer’s hard drive that enables the website to identify your computer as you view different pages. Cookies allow websites and applications to store your preferences in order to present contents, options or functions that are specific to you. Like most interactive websites, our website uses cookies to enable the tracking of your activity for the duration of a session. Our website uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the browser. Session cookies do not collect information from the user’s computer. They will typically store information in the form of a session identification that does not personally identify the user. 6.0 How we protect your personal information We store and process your personal information on our computers in Nigeria. Where we need to transfer your data to another country, such country must have an adequate data protection law. We will seek your consent where we need to send your data to a country without an adequate data protection law. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. 7.0 How We Share your information within SWAPITWAY and other users During your interaction with any of our platforms or premises, we may provide Ministries, Departments, Agencies (MDAs), other organs of government, private sector operators performing government functions, with information such as your name, contact details, or other details you provide us for the purpose of performing their statutory mandate to you or third parties. We work with third parties, banks, financial institutions and corporate bodies to perform SWAPITWAY services and implement its mandate. In doing so, a third party may share information about you with us, such as your email address or mobile phone number. You accept that your pictures and testimonials on all social media platforms about SWAPITWAY can be used for limited promotional purposes by us. This does not include your trademarked or copyrighted materials. From time to time we may send you relevant information such as news items, enforcement notice, statutorily mandated notices and other informative notices to help SWAPITWAY serve you better. We may also share your personal information in compliance with National or international laws; crime prevention and risk management agencies and service providers. 8.0 Security We promise to and will always hold your information securely. To prevent unauthorized access to your information, we have implemented strong controls and security safeguards at the technical and operational levels. You should see the padlock symbol in your URL address bar once you are successfully logged into the platform. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your device and the connecting server. Any data transmitted during the session will be encrypted before transmission and decrypted at the receiving end. This is to ensure that data cannot be read during transmission. SWAPITWAY has also taken measures to comply with global Information Security Management Systems (ISMS) we therefore have put in place digital and physical security measures to limit or eliminate possibilities of data privacy breach incidents. 9.0 Data Confidentiality Rights Your information is regarded as confidential and will not be divulged to any third party except under legal and/or regulatory conditions. You have the right to request sight of, and copies of any and all information we keep on you. While SWAPITWAY is responsible for safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes, but is not limited to, adopting and enforcing appropriate security measures such as non-sharing of passwords and other platform login details, adherence with physical security protocols on our platforms, dealing with only authorized officers of SWAPITWAY. 10.0 Links to Other Websites and Premises Certain transaction processing channels may require links to other websites other than ours. Please note that SWAPITWAY is not responsible and has no control over websites outside its domain. We do not monitor or review the content of other party’s websites which are linked from our website or media platforms. Opinions expressed or materials appearing on such websites are not necessarily shared or endorsed by us, and SWAPITWAY should not be regarded as the publisher of such opinions or materials. Please be aware that we are not responsible for the privacy practices, or content of these sites. We encourage our users to be aware of when they leave our site and to read the privacy statements of these sites. You should evaluate the security and trustworthiness of any other site connected to this site or accessed through this site yourself, before disclosing any personal information to them. SWAPITWAY will not accept any responsibility for any loss or damage in whatever manner, howsoever caused, resulting from your disclosure to third parties of personal information. 11.0 Governing Law This Privacy Policy is made pursuant to and in compliance with the Nigeria Data Protection Regulation (2019) and other relevant Nigerian laws, regulations or international conventions applicable to Nigeria. Where any provision of this Policy is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention. COOKIES POLICY Cookies are small text files which are transferred from our websites, apps, platforms or portals and stored on your device. We use cookies to help us provide you with a personalized service, and to help make our websites or portals better for you. Our cookies may be session cookies (temporary cookies that identify and track users within our websites or portals which are deleted when you close your browser or leave your session) or persistent cookies (cookies which enable our websites or portals to “remember” who you are and to remember your preferences within our websites or portals and which will stay on your computer or device after you close your browser or leave your session We use the following different types of cookies: Essential cookies These are cookies which are needed for our websites or portals to function properly, for example, these cookies allow you to access secure areas of our website/portal. Performance cookies. These cookies collect information about how visitors and users use our websites and portals. These cookies don’t collect information that identifies a visitor or user. All information these cookies collect is aggregated and therefore anonymous. We only use these cookies to improve how our website and portal. Functionality cookies. These cookies allow our websites and portals to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites. Like most interactive websites, our website uses cookies to enable the tracking of your activity for the duration of a session. Our website uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the browser. Session cookies do not collect information from the user’s computer. They will typically store information in the form of a session identification that does not personally identify the user. DATA PROTECTION POLICY SWAPITWAY Data Protection Policy refers to our commitment to treat information of employees, customers, stakeholders and other interested parties with the utmost care and confidentiality. With this policy, we ensure that we gather, store and handle data fairly, transparently and with respect towards individual rights. Scope This policy refers to all parties who provide any amount of information to us. What is covered under the Data Protection Policy? SWAPITWAY employees must follow this policy. Freelancers, consultants, partners and any other external entity are also covered. Generally, our policy refers to anyone we collaborate with or acts on our behalf and may need occasional access to data. Policy Elements As part of our operations, we need to obtain and process information. This information includes any offline or online data that makes a person identifiable such as names, addresses, usernames and passwords, digital footprints, photographs, National identity numbers, financial data etc. SWAPITWAY collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply. Our data will be: Accurate and kept up-to-date; Collected fairly and for lawful purposes only; Processed by the company within its legal and moral boundaries; Protected against any unauthorized or illegal access by internal or external parties. Our data will not be: Transferred to organizations, states or countries that do not have adequate data protection policies; Distributed to any party other than the ones agreed upon by the data’s owner (exempting legitimate requests from law enforcement authorities). In addition to ways of handling data, SWAPITWAY has direct obligations towards people to whom the data belongs. Specifically we: Let people know which of their data is collected; Inform people about how we’ll process their data; Inform people about who has access to their information; Have provisions in cases of lost, corrupted or compromised data; Allow people to request that we modify, erase, reduce or correct data contained in our databases° Actions To exercise data protection we’re committed to: Restricting and monitoring access to sensitive data; Developing transparent data collection procedures; Training employees in online privacy and security measures; Building secure networks to protect online data from cyberattacks; Establishing clear procedures for reporting privacy breaches or data misuse; Including contract clauses or communicate statements on how we handle data; Establishing data protection practices.