Swijin AG collects some Personal Data from its Users.

This document contains a section dedicated to Users in Switzerland and their privacy rights.

This document contains a section dedicated to Users in the United States and their privacy rights.

Owner and Data Controller
Swijin AG Lerchenfeldstr. 3, 9014 St. Gallen, Switzerland
Owner contact email: hello@swijin.com

Types of Data collected
Among the types of Personal Data that Swijin AG collects, by itself or through third parties, there are: email address; first name; last name; Tracker; Usage Data; billing address; shipping address; payment info; device information; physical address; phone number; ZIP/Postal code; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Data communicated while using the service; Universally unique identifier (UUID).

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using swijin.com. Unless specified otherwise, all Data requested by swijin.com is mandatory and failure to provide this Data may make it impossible for swijin.com to provide its services. In cases where swijin.com specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by swijin.com or by the owners of third-party services used by swijin.com serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document.

Users are responsible for any third-party Personal Data obtained, published or shared through swijin.com and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of swijin.com (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Managing contacts and sending messages, Analytics, Platform services and hosting, Handling payments, Advertising, Tag Management, Interaction with data collection platforms and other third parties, Traffic optimization and distribution, Interaction with live chat platforms, Content performance and features testing (A/B testing), Displaying content from external platforms, Commercial affiliation, Contacting the User, Registration and authentication provided directly by swijin.com and Remarketing and behavioral targeting.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data Personal Data is collected for the following purposes and using the following services: Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on swijin.com, possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside swijin.com. For more information, please check the privacy policies of the relevant services. Services of this kind usually offer the possibility to opt-out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt-out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

Teads (Teads SA)
Teads is an advertising service provided by Teads SA. Personal Data processed: Tracker; Usage Data. Place of processing: Luxembourg – Privacy Policy – Opt out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes sale in California

Google Ads conversion tracking (Google LLC)
Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on swijin.com. Personal Data processed: Trackers; Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes sale in California

Meta ads conversion tracking (Meta pixel) (Meta Platforms, Inc.)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta Audience Network with actions performed on swijin.com. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network. Personal Data processed: Trackers; Usage Data. Place of processing: United States – Privacy Policy – Opt out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes sale in California

Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Universal Analytics) (Google LLC)
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of swijin.com, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. In order to understand Google's use of Data, consult Google's partner policy. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes sale in the United States

Google Analytics Advertising Reporting Features (Google LLC)
Google Analytics on swijin.com has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about age and gender). Users can opt out of Google's use of cookies by visiting Google's Ads Settings. Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. This processing constitutes sale in California

Google Analytics 4 (Google Ireland Limited)
Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of swijin.com, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation. In order to understand Google's use of Data, consult Google's partner policy. Personal Data processed: Trackers. Place of processing: Ireland – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes sale in California

Commercial affiliation
This type of service allows swijin.com to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics. Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with swijin.com. For details of which data are collected, please refer to the privacy policy of each service.

Contacting the UserContact form (swijin.com)
By filling in the contact form with their Data, the User authorizes swijin.com to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header. Personal Data processed: email address; first name. Category of Personal Information collected according to the CCPA: identifiers. This processing constitutes:
a Sale in California

Mailing list or newsletter (swijin.com)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning swijin.com. Your email address might also be added to this list as a result of signing up to swijin.com or after making a purchase. Personal Data processed: email address. Category of Personal Information collected according to the CCPA: identifiers. This processing constitute sale in the United States

Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of swijin.com.

Google Optimize (Google LLC)
Google Optimize is an A/B testing service provided by Google LLC ("Google"). Google may use Personal Data to contextualize and personalize the ads of its own advertising network. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes sale in California

Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of swijin.com and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Handling payments
Unless otherwise specified, swijin.com processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Swijin.com isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Google Pay (Google Ireland Limited)
Google Pay is a payment service provided by Google Ireland Limited, which allows users to make online payments using their Google credentials. Personal Data processed: Trackers. Place of processing: Ireland – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Klaviyo (Klaviyo Inc.)
Klaviyo is an email address management and message sending service provided by Klaviyo Inc. To take advantage of the service provided by Klaviyo, the Owner typically shares information about (purchasing) Users, such as for example contact details and shopping histories. Check the indication at “Personal Data processed“ below for an explanation of the extent of the sharing. Personal Data processed: Trackers. Place of processing: United States – Privacy Policy – Opt out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes sale in California and Sharing in California

Platform services and hosting
These services have the purpose of hosting and running key components of swijin.com, therefore allowing the provision of swijin.com from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Shopify (Shopify Inc.)
Shopify is a platform provided by Shopify Inc. that allows the Owner to build, run and host an e-commerce website. Personal Data processed: billing address; email address; first name; last name; payment info; shipping address. Place of processing: Canada – Privacy Policy. Category of Personal Information collected according to the CCPA: identifiers; commercial information.

Registration and authentication provided directly by swijin.com
By registering or authenticating, Users allow swijin.com to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

Direct registration (swijin.com)
The User registers by filling out the registration form and providing the Personal Data directly to swijin.com. Personal Data processed: email address; first name. Category of Personal Information collected according to the CCPA: identifiers.

Remarketing and behavioral targeting
This type of service allows swijin.com and its partners to inform, optimize and serve advertising based on past use of swijin.com by the User. This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity. Some services offer a remarketing option based on email address lists. Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.

Tag Management
This type of service helps the Owner to manage the tags or scripts needed on swijin.com in a centralized fashion. This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC. Personal Data processed: Tracker. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes sale in California

Traffic optimization and distribution
This type of service allows swijin.com to distribute their content using servers located across different countries and to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between swijin.com and the User's browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document. The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps. Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Further Information for Users Legal basis of processing
The Owner may process Personal Data relating to Users under specific conditions: when Users have given consent for one or more specific purposes; when the provision of Data is necessary for the performance of an agreement with the User or for any pre-contractual obligations; when processing is required for compliance with a legal obligation to which the Owner is subject; when processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Owner; or when processing is necessary for the legitimate interests pursued by the Owner or a third party. In any case, the Owner will assist in clarifying the specific legal basis for the processing, particularly whether the provision of Personal Data is statutory or contractual.

Further information about retention time
Unless specified otherwise in this document, Personal Data will be processed and stored for as long as necessary to fulfill the purposes for which it was collected, and it may be retained longer if required by applicable legal obligations or based on the User’s consent. Personal Data collected for the performance of a contract between the Owner and the User will be retained until the contract is fully executed. Personal Data collected for the Owner’s legitimate interests will be retained as long as necessary to achieve those interests. Users can find specific information regarding these legitimate interests within the relevant sections of this document or by contacting the Owner. The Owner may also retain Personal Data for a longer period if the User has given consent, provided that such consent is not withdrawn. Additionally, the Owner may be required to retain Personal Data for a longer duration to comply with legal obligations or upon the order of an authority. Once the retention period expires, Personal Data will be deleted, making it impossible to enforce the right of access, erasure, rectification, or data portability after this period.

The rights of Users based on the General Data Protection Regulation (GDPR)
Users have certain rights regarding their Data processed by the Owner, which they may exercise as permitted by law. These rights include the following: the right to withdraw consent at any time if they have previously consented to the processing of their Personal Data; the right to object to the processing of their Data if it is based on a legal basis other than consent; the right to access their Data, including confirming whether it is being processed, obtaining details about the processing, and receiving a copy of the Data; the right to verify the accuracy of their Data and request corrections or updates; the right to restrict the processing of their Data, meaning the Data will only be stored and not processed for other purposes; the right to have their Personal Data deleted or removed; the right to receive their Data in a structured, commonly used, and machine-readable format, and if technically feasible, have it transferred to another controller without hindrance; and the right to lodge a complaint with their competent data protection authority. Additionally, Users have the right to learn about the legal basis for any Data transfers abroad, including to international organizations governed by public international law, such as the UN, and the security measures the Owner has implemented to protect their Data.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge, and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Further information for Users in Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.

The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of the law, including the following: the right of access to their Personal Data; the right to object to the processing of their Personal Data, which also includes the ability to demand that the processing be restricted, the Data be deleted or destroyed, or specific disclosures of Data to third parties be prohibited; the right to receive their Personal Data and have it transferred to another controller (data portability); and the right to request the correction of any incorrect Personal Data.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.

The grounds on which we process your personal information
We can process your personal information only if we have a valid legal basis for doing so. These legal bases include: your consent to the specific processing activities; compliance with legal or regulatory obligations that apply to us; the implementation of public policies outlined in laws or regulations, or those based on contracts, agreements, and similar legal instruments; studies conducted by research entities, preferably using anonymized personal information; the execution of a contract and its preliminary procedures when you are a party to that contract; the exercise of our rights in judicial, administrative, or arbitration procedures; the protection of your or a third party’s physical safety; the protection of health in procedures carried out by health entities or professionals; our legitimate interests, provided that your fundamental rights and liberties do not override those interests; and credit protection. For more details about these legal bases, you can contact us at any time using the contact information provided in this document.

Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information, subject to applicable law. These rights include: the right to access your Personal Information, which allows you to request confirmation on whether we are processing your data and to access it if we are; the right to correct inaccurate Personal Information, enabling you to request corrections to any incorrect data we hold about you; the right to request the deletion of your Personal Information, allowing you to ask us to delete your data; the right to obtain a copy of your Personal Information in a portable and usable format, facilitating easy transfer to another entity, provided this is technically feasible; the right to opt-out of the sale of your Personal Information; and the right to non-discrimination, ensuring you are not treated unfairly for exercising your privacy rights.

Additional rights for Users residing in California
IIn addition to the rights listed above that are common to all Users in the United States, as a User residing in California, you also have the following rights: the right to opt-out of the sharing of your Personal Information for cross-context behavioral advertising; and the right to request that we limit our use or disclosure of your Sensitive Personal Information to only what is necessary to perform services or provide goods as reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our services.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, and Montana
In addition to the rights listed above that apply to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, and Oregon, you also have the following rights: the right to opt-out of the processing of your personal information for Targeted Advertising or profiling that leads to decisions with legal or similarly significant effects concerning you; and the right to freely give, deny, or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions may apply as outlined in the law, such as when the collection and processing of Sensitive Personal Information is necessary for providing a product or service specifically requested by you.

Additional rights for users residing in Utah
In addition to the rights listed above that are common to all Users in the United States, as a User residing in Utah, you also have the following rights: the right to opt-out of the processing of your Personal Information for Targeted Advertising; and the right to opt-out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by you.

How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document. For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes. If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt-out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on swijin.com. If you want to submit requests to opt-out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need. Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint). We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Additional information about Data collection and processingLegal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of swijin.com or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data
In addition to the information contained in this privacy policy, swijin.com may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, swijin.com and any third-party services may collect files that record interaction with swijin.com (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within swijin.com and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references Personal Data (or Data) / Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.

Usage Data
Information collected automatically through swijin.com (or third-party services employed in swijin.com), which can include: the IP addresses or domain names of the computers utilized by the Users who use swijin.com, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User
The individual using swijin.com who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of swijin.com. The Data Controller, unless otherwise specified, is the Owner of swijin.com.

Swijin.com (or this Application)
The means by which the Personal Data of the User is collected and processed.

Service
The service provided by swijin.com as described in the relative terms (if available) and on this site/application.

Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.

Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.

Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie
Cookies are Trackers consisting of small sets of data stored in the User’s browser.

Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information
This privacy statement has been prepared based on provisions of multiple legislations. This privacy policy relates solely to swijin.com, if not stated otherwise within this document.

Latest update: August 8, 2024