Privacy Policy

Last updated 26th November, 2018

Who are we?

Swancy AS («Swancy»), a Norwegian private limited company, reg. nr. 818 853 742, is the developer and proprietor of the Swancy application («Swancy App») and the website swancyapp.com.

How do we collect information from you?

The intention of the Swancy App is a to facilitate promotion of sustainable fashion and reuse of clothing by operating an application-based marketplace where Users can swap clothes with each other (the “Services”). To facilitate the Services, it is necessary for Swancy to process certain types of personal data from you as a User. Swancy therefore obtains personal data about you when you create a user profile, and use the Swancy App.

We use your personal data and information to provide and improve the Services in accordance with the Terms & Conditions. By using the Services, you agree to the collection and use of personal data in accordance with this privacy policy (the “Privacy Policy”). Unless otherwise defined in this Privacy Policy, terms used shall have the same meanings as in our Terms & Conditions.

The legal basis for processing your personal data is the regulation under the EC Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data.

For the newsletter the legal basis for processing personal data is your consent given when signing up for the newsletter.

What type of information is collected from you and how does Swancy use this data?

The Swancy App is a peer-to-peer platform, and in order to provide the Services it is necessary to disclose some personal data about you to other Users of the Swancy App.

While using our Services, we may therefore ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable data may include, but is not limited to your e-mail address, first and last name, phone number, address (including State, Province, ZIP/Postal Code, City), and cookies and usage data.

The personal data accessible for other Users is only your username, pictures and text that you have chosen to disclose to use the Services in the Swancy App.

Personal Data is collected for the following purposes and using the following services:

Type of information

Email, password, username, token

Where is it stored?

Auth0

Purpose

This information is required in order to create a unique login. Users can opt-in to be notified by email when they get a new match, or message in the App. A Token with the User's login information is saved in order to keep the User logged in.


Type of information

Full name and address

Where is it stored?

Amazon AWS

Purpose

These fields will later be used to provide the user with secure shipping options. For the time being, it is also used for statistical purposes, to mark out where the users are located.


Type of information

Cookies, usage data

Where is it stored?

Google Analytics

Purpose

Collects anonymous usage data such as device information, sessions, position (country and city) session duration and screen views. The information is strictly collected to help us to improve our Services and operations.


Type of information

Name, Email

Where is it stored?

MailChimp

Purpose

The user may opt-in to receive our newsletter. This information is stored with our third-party e-mail marketing service, MailChimp. MailChimp certified its agreement to the Privacy Shield Framework.


Type of information

Camera permission/image storage

Where is it stored?

Device/AWS

Purpose

Camera permission is required to be able to upload an item to swap. The image is stored on our server.


Type of information

Geolocation

Where is it stored?

Device/AWS

Purpose

Permission to access phone location when entering the app is required to identify what items to show the user, and to make the user's item visible to nearby users. The user's item's approximate whereabouts is visible to other users.

Any use of Cookies, or other tracking tools, by the Swancy App or by the owners of third-party services used by the Swancy App serves the purpose of providing the Services required by the User, in addition to any other purposes described in the Web Tokens and Cookies Policies below.

Swancy also uses Tokens as described in the table above. Tokens are an encoded string of personal information which is used during the exchange of data with our server. Note that third-party processor Auth0 may retain information in accordance with their own privacy policy. Auth0’s full privacy policy is available here: https://auth0.com/privacy.

Swancy will not share personal information with third-parties, nor transfer the personal data to a third country unless stated in the column above. Some personal data may however be accessible to certain types of persons in charge, involved with the operation of the Swancy App (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies). An updated list of data processors may be requested from Swancy at any time.

Swancy retains personal data about you for as long as you are registered as a User on the Swancy App.

Your rights as a data subject:

You have the right to i) access, ii) correct, and/or iii) delete personal data about you. You also have the right to object to the processing of personal data and to exercise your rights of data portability. If you would like a copy of personal data collected from you, please let us know by email: contact@swancyapp.com.

You have the right to send a complaint to the supervisory authority (Datatilsynet).

As a receiver of the newsletter you may at any time revoke your consent by sending a request to contact@swancyapp.com or by following the unsubscribe link in each newsletter.

Security of processing:

Swancy processes the personal data in a proper manner and will take all reasonable steps to maintain appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the personal data.

The security of your data is very important to us but remember that no method of transmission over the internet, or method of electronic storage is 100 % secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

Children's privacy

Our Services does not address anyone under the age of 18, and we do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or legal guardian and you are aware that your children have provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

General

Swancy may update the Privacy Policy from time to time. We will notify you of any changes and ask you to accept them before continuing to use the Services.

We will let you know via email and/or a prominent notice on the Swancy App prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy. 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.

JSON Web Tokens policy

A JSON Web Token (JWT) is a small piece of data sent from a website and installed in the Swancy App to assist Swancy in providing the Service according to the purposes described in this document and the Terms & Conditions. The Swancy App uses Tokens from certain third-party service providers to save the User’s session and to carry out other activities that are strictly necessary for the operation of the Swancy App, for example in relation to the distribution of traffic.

The third-party service providers who are using JSON Web Tokens are listed below.

Auth0

Auth0 is a registration and authentication service by Auth0, Inc. By registering or authenticating, Users allow Swancy to identify them and give them access to dedicated services.

Personal data collected: JSON Web Token, email address, username, password.

Place of processing: US – Privacy policy.

Cookie policy

A Cookie is a small text file that is stored on a User’s phone/computer for record-keeping purposes. Swancy does not itself store Cookies, but uses certain third-party service providers that themselves use Cookies to collect statistics in an anonymized and aggregated form. The third-party service providers who collect data by using Cookies are listed below.

Google Analytics

Google Analytics is a web-based service provided by Google Inc. (Google). Google Analytics store Cookies and usage data that enable Swancy to keep track of User behavior, and to monitor and analyze traffic on the Swancy App and the website swancyapp.com.

Personal data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy.

Contact us

In order to resolve a complaint regarding the Services or to receive further information regarding use of the Services, please contact us at:

Swancy AS
Thormøhlensgate 51, 5006 Bergen
+47 90876786
contact@swancyapp.com