Privacy Policy

1. Introduction

swapfi.org (operated by Cow DAO Technologies LLC, registered in New York, USA) values your privacy. This Privacy Policy explains our practices regarding the collection, use, storage, and disclosure of personal data when you visit our website at https://swapfi.org or use our decentralized finance (DeFi) and cryptocurrency-related services. By accessing or using our platform, you acknowledge that you have read and understood this policy.

We comply with applicable data protection laws in the United States, including but not limited to the California Consumer Privacy Act (CCPA) as amended, and respect the privacy rights of users globally. If you are located in the European Economic Area (EEA) or the United Kingdom, additional rights under the General Data Protection Regulation (GDPR) may apply to you as described below.

2. Information We Collect

2.1 Information You Provide Directly

When you fill out a contact form, subscribe to our newsletter, request a consultation, or otherwise communicate with us, we may collect:

• Your full name and email address
• Phone number (if provided)
• Company name and job title (if applicable)
• Any message or inquiry you submit
• Wallet address (if you voluntarily share it for support or partnership inquiries)

2.2 Information Collected Automatically

When you visit our website, we automatically collect certain technical data through cookies and similar tracking technologies:

• IP address and approximate geolocation (city/region level)
• Browser type, version, and language preferences
• Operating system and device type
• Pages viewed, time spent on pages, click patterns, and referring URLs
• Session duration and interaction with site features

2.3 Information from Third Parties

We do not actively purchase personal data from third parties. However, if you engage with us through partner platforms, social media channels, or advertising networks (such as Google Ads), we may receive aggregated or anonymized analytics data that does not directly identify you. We require any third-party data sources to have obtained your consent or have a lawful basis for sharing such information.

3. How We Use Your Information

We use the collected data for the following legitimate business purposes:

• Service delivery: To respond to your inquiries, provide information about our DeFi services, and facilitate communications.
• Improvement: To analyze website usage patterns and enhance user experience, content relevance, and site performance.
• Marketing (with consent): To send newsletters, updates, and promotional materials about our services if you have opted in. You may unsubscribe at any time.
• Compliance: To comply with applicable legal obligations, including anti-money laundering (AML) and know-your-customer (KYC) requirements where relevant, and to enforce our Terms of Service.
• Security: To detect, prevent, and address fraud, unauthorized access, or other technical security issues.

4. Data Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties for their own marketing purposes. We may share your data only in the following circumstances:

• Service providers: With trusted third-party vendors who assist us in operating our website, processing communications, analyzing data, or delivering services (e.g., hosting providers, email delivery services, analytics platforms). These providers are contractually bound to protect your data and may only use it for the purposes we specify.
• Legal compliance: If required by law, regulation, legal process, or governmental request (including to meet national security or law enforcement requirements), we may disclose your information. We will make reasonable efforts to notify you unless prohibited by law.
• Business transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your data may be transferred as part of that transaction. We will notify you via email or a prominent notice on our website of any change in ownership or use of your data.
• With your consent: We may share your information for any other purpose disclosed to you at the time of collection, provided we have obtained your explicit consent.

5. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable law. Specifically:

• Contact form submissions and correspondence are retained for up to 24 months after the last interaction, unless a longer retention period is required by law.
• Analytics data (IP addresses, browsing patterns) is retained in aggregated form for up to 26 months.
• If you subscribe to our newsletter, we retain your email address until you unsubscribe or request deletion.
• Records related to legal or regulatory compliance (e.g., AML/KYC documentation, if applicable) are retained in accordance with relevant statutory periods, typically 5 years after the end of the business relationship.

When data is no longer needed, we securely delete or anonymize it. In some cases, data may be retained longer in backup archives, but access is restricted and retention is minimized.

6. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal data:

6.1 For All Users

• Access: You may request a copy of the personal data we hold about you.
• Correction: You may ask us to correct any inaccurate or incomplete information.
• Deletion: You may request deletion of your personal data, subject to certain legal exceptions (e.g., compliance with law, fraud prevention).
• Opt-out of marketing: You may unsubscribe from marketing communications at any time by clicking the "unsubscribe" link in our emails or contacting us directly.

6.2 For California Residents (CCPA)

If you are a California resident, you have the additional right to:

• Know what personal information we collect, use, disclose, and sell (we do not sell personal information).
• Request disclosure of the specific pieces of personal information we have collected about you in the preceding 12 months.
• Request deletion of your personal information (subject to exceptions).
• Opt out of the sale of your personal information (we do not engage in such sales).
• Non-discrimination: We will not deny you services or charge different prices based on your exercise of CCPA rights.

To exercise your CCPA rights, please contact us using the information in Section 10. We will verify your identity using reasonable methods before processing your request.

6.3 For EEA/UK Residents (GDPR)

If you are located in the European Economic Area or the United Kingdom, you have the following additional rights:

• Right to rectification: Request correction of inaccurate data.
• Right to erasure ("right to be forgotten"): Request deletion of your data where it is no longer necessary for the purpose collected, or you withdraw consent.
• Right to restrict processing: Request that we limit how we use your data in certain circumstances.
• Right to data portability: Request a copy of your data in a structured, machine-readable format and have it transmitted to another controller where technically feasible.
• Right to object: Object to processing based on legitimate interests, including direct marketing.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise your GDPR rights, contact us at [email protected]. We will respond within one month (extendable by two months for complex requests). You also have the right to lodge a complaint with your local data protection supervisory authority.

7. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze site traffic, and support our marketing efforts. For full details, please see our separate Cookie Policy. In summary:

• Essential cookies: Required for the website to function properly (e.g., session management, security). These cannot be disabled.
• Analytics cookies: We use Google Analytics and similar services to understand how visitors interact with our site. Data collected is anonymized where possible (e.g., IP masking).
• Marketing cookies: With your consent, we may use cookies from Google Ads and other platforms to deliver relevant advertisements and measure campaign performance.

You can manage your cookie preferences through our cookie consent tool (accessible via the "Cookie Settings" link in the footer) or by adjusting your browser settings. Disabling certain cookies may affect site functionality.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS 1.3 protocols.
• Secure server infrastructure with firewalls and intrusion detection systems.
• Access controls limiting data access to personnel who need it to perform their job functions.
• Regular security audits and vulnerability assessments.
• Employee training on data protection and privacy practices.

While we strive to protect your data, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we take all reasonable steps to safeguard your information. In the event of a data breach that affects your personal data, we will notify you and the relevant supervisory authority as required by applicable law.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your own, including the United States where our servers and primary operations are located. When we transfer data from the EEA/UK to the US, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) adopted by the European Commission, or other lawful transfer mechanisms. By providing your data, you consent to such transfers subject to these safeguards.

10. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us using the following details:

• Email: [email protected] (for privacy-specific inquiries) or [email protected] (general inquiries)
• Phone: +1 212 739 4821
• Mailing Address: Cow DAO Technologies LLC, 350 Fifth Avenue, Suite 3304, New York, NY 10118, USA

We aim to respond to all legitimate requests within 10 business days. For urgent data protection matters, please mark your correspondence "ATTN: Privacy Officer" to ensure prompt handling.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make material changes, we will notify you by posting the updated policy on this page with a revised "Last updated" date at the top. For significant changes that affect your rights, we may also provide additional notice via email (if we have your email address) or a prominent banner on our website. We encourage you to review this policy periodically to stay informed about how we are protecting your information.

12. Third-Party Links and Services

Our website may contain links to third-party websites, platforms, or services that are not owned or controlled by us. This includes links to DeFi protocols, wallet providers, social media channels, and partner sites. We are not responsible for the privacy practices or content of these third parties. We encourage you to review the privacy policies of any third-party services you interact with before providing your personal information. This Privacy Policy applies solely to information collected by swapfi.org.

13. Children's Privacy

Our services are not directed to individuals under the age of 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal data without verifiable parental consent, we will take steps to delete that information promptly. If you believe we may have collected data from a child, please contact us immediately at [email protected].

14. Governing Law and Dispute Resolution

This Privacy Policy is governed by and construed in accordance with the laws of the State of New York, United States, without regard to its conflict of law principles. Any disputes arising out of or related to this policy shall be resolved through binding arbitration in New York County, New York, in accordance with the rules of the American Arbitration Association. You agree to resolve any claims on an individual basis and waive the right to participate in any class action or representative proceeding, to the fullest extent permitted by law.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may contact the Federal Trade Commission (FTC) at ftc.gov/complaint or the data protection authority in your country of residence (for EEA/UK residents).