PRIVACY POLICY — SWINGX
Effective Date: July, 5, 2025

Jurisdiction: International (Compliant with GDPR, CCPA, LGPD, and other major data protection frameworks)

This Privacy Policy outlines how SwingX ("we", "our", "the App") collects, processes, shares, and protects your data when you use our application and services. By using SwingX, you agree to the terms of this Privacy Policy.

WHO WE ARE

SwingX is a global social networking platform exclusively for adults (18+) seeking consensual, exploratory connections, whether as individuals or couples.

INFORMATION WE COLLECT

We may collect the following categories of information:

Account Data: name or alias, email, age, gender identity, orientation, language, preferences, and country.

Profile Data: photos, videos, bio, relationship status, kinks, interests, and couple link.

Usage Data: messages, likes, comments, posts, reports, session timestamps, clicks, and featureinteractions.

Device Data: device type, OS, IP address, app version, advertising ID, cookies, and location (if enabled).

Payment Data: subscription and transaction metadata (processed via Apple/Google, not stored by us).

HOW WE USE YOUR DATA

We use your data to:

Create and manage your account (single or couple)

Facilitate matching, messaging, and discovery features

Deliver subscription services and process payments

Moderate content and uphold platform safety

Provide customer support and respond to inquiries

Personalize user experience based on behavior and preferences

Comply with legal obligations and prevent fraud

COUPLE ACCOUNTS AND USER DEPARTURE

Couple Accounts grant both users full, mutual access to all activity, messages, and settings.

If one member exits the Couple Account:

All media, profile elements, and posts related to that user are permanently deleted (hard delete).

Shared chat remains accessible but is labeled with "User Left".

No backups of deleted user content are retained.

LINKS AND CLICK TRACKING

When using SwingX, we may track interactions with internal and external links to improve safety and user experience.

We do not track behavior outside the App.

MESSAGE ANALYSIS (ANONYMIZED)

We may use anonymized and aggregated message data to identify trends and improve features. No personal message content is analyzed or shared.

TESTIMONIALS, SURVEYS, AND MARKETING

Participate in surveys, Share a testimonial (with explicit consent), Feature in campaigns (optional and revocable), You may decline at any time via privacy@swingx.app or in your settings.

CUSTOMER SUPPORT AND RECORD RETENTION

When contacting support, we retain your correspondence and relevant metadata (e.g. IP, device) for up to 6 years post-account deletion, for legal and security purposes.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies to: Enable core functionality, Remember preferences and Prevent abuse or fraud.

DEVICE AND LOCATION DATA

If permitted by you, we may collect: General or precise location, Device identifiers, model, OS, and time zone Wi-Fi or network data This is used for regional relevance and connection features.

CONTENT MODERATION AND ENFORCEMENT

We monitor SwingX using human moderation to enforce our Terms and Community Guidelines.

Violations may lead to suspension or removal. Appeals may be submitted to support.

DATA SHARING WITH TRUSTED PROVIDERS

We may share data with:

Infrastructure providers (AWS, GCP)

Payment processors (Apple, Google)

Authentication tools (Twilio)

Analytics tools (Mixpanel, Amplitude)

Marketing platforms (e.g. Meta Ads)

Customer support systems (e.g. Zendesk) All partners access only what is necessary for their function.

LEGAL COMPLIANCE AND HARM PREVENTION

We may disclose personal data:

To comply with legal obligations or court orders

To protect users or third parties from harm

To detect, investigate, or prevent fraud or abuse We challenge unlawful requests and protect user privacy wherever legally permissible.

BUSINESS TRANSFERS

If SwingX undergoes a merger, acquisition, asset sale, or reorganization, your data may be transferred. You will be notified of any material changes.

ANTI-FRAUD AND ANTI-SPAM MEASURES

We monitor for suspicious activity to prevent fraud and abuse, including: Linked accounts or devices, Payment fraud and chargebacks, Spam patterns or impersonation attempts We may use IP, device ID, email, social login, and transactional metadata.

AGGREGATED AND NON-IDENTIFIABLE DATA

We may publish or share anonymized usage statistics (e.g. regional data, trends). These cannot be linked back to individual users.

INTERNATIONAL DATA TRANSFERS

Your data may be processed outside your country (e.g. US, EEA). We implement safeguards such as Standard Contractual Clauses for lawful international transfers.

INTERNATIONAL DATA TRANSFERS

Your data may be processed outside your country (e.g. US, EEA). We implement safeguards such as Standard Contractual Clauses for lawful international transfers.

YOUR RIGHTS

Depending on your jurisdiction, you may:

Access or correct your data, request deletion or restriction, withdraw consent, object to data processing, export your data (portability), file a complaint with your Data Protection Authority Requests: privacy@swingx.app

DATA RETENTION

Active accounts: data retained during account lifetime.

Deleted accounts: all personal data is erased immediately unless retention is legally required (e.g. financial records). Billing data: retained for up to 10 years to comply with tax and regulatory requirements.

Couple member exits: all personal content of the exiting user is hard-deleted; only anonymized chat remains.

CHILDREN'S PRIVACY

SwingX is only for users aged 18 or older. We do not knowingly collect data from minors. Underage accounts will be terminated and reported.

POLICY CHANGES

We may update this policy from time to time. Users will be notified of significant changes via in-app notice or email. Continued use of SwingX indicates acceptance.

UNITED STATES PRIVACY ADDENDUM

SwingX complies with applicable U.S. state privacy laws, including:

California Consumer Privacy Act (CCPA)

Virginia Consumer Data Protection Act (VCDPA)

Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA)

Utah Consumer Privacy Act (UCPA)

We honor your rights under these laws, including rights to access, deletion, and opt-out of data sale.

CONTACT

To request data access, deletion, or submit concerns, contact: privacy@swingx.

app Legal Entity: Dalbott LDA
Registered in: Portugal