Privacy Policy – Swaréy

Last updated: 20/01/2026

1. Data Controller

Swaréy Services

Sole proprietorship established in Belgium

Email: info@swarey.app

Swaréy Services (hereinafter 'Swaréy') is responsible for processing personal data as described in this privacy policy, in accordance with Regulation (EU) 2016/679 (GDPR).

2. Personal Data We Process

Swaréy processes personal data of individuals, professional users and self-employed workers using the platform.

The categories of data that may be processed include:

• First name and last name
• Company name
• Email address
• Phone number
• Information related to the user account
• Professional profile content (description, photos, portfolio, location)
• Technical data (IP address, device type, operating system, navigation and application usage information)

No sensitive data within the meaning of the GDPR is processed.

3. How We Collect Personal Data

Personal data is collected when the user:

• Creates an account on the platform
• Completes or modifies their profile
• Uses the services offered
• Subscribes to a subscription
• Communicates with Swaréy via the application or by email

4. Purposes of Processing

Personal data is processed exclusively for the following purposes:

• Creation and management of user accounts
• Provision and execution of platform services
• Publication and visibility of professional profiles
• Communication between Swaréy and users
• Administrative management and billing
• Improvement, security and optimization of the platform
• Compliance with legal and regulatory obligations

5. Legal Basis for Processing

In accordance with Article 6 of the GDPR, processing is based on the following legal bases:

• Performance of the contract concluded with the user
• Compliance with legal obligations, particularly in accounting and tax matters
• Swaréy's legitimate interest in ensuring proper functioning, security and improvement of the platform
• Explicit user consent when required (particularly for certain cookies or communications)

6. Payments

Payments are processed by an external payment service provider, Stripe.

Swaréy never has access to complete payment card data and does not retain any sensitive banking information.

Stripe acts as an independent data controller for payment operations and declares itself compliant with the GDPR.

For more information: https://stripe.com/privacy

7. Sharing Personal Data with Third Parties

Personal data may only be shared when strictly necessary with:

• Technical providers (hosting, infrastructure, maintenance)
• Payment service providers
• Analytics and communication providers
• Competent authorities when required by law

These providers act exclusively as processors and process data solely according to Swaréy's instructions, under GDPR-compliant agreements.

Personal data is never sold to third parties.

8. Transfers of Data Outside the European Union

Some data may be transferred outside the European Union, particularly when technical or payment providers are located outside the EU.

In such cases, Swaréy ensures that appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission or any other GDPR-compliant measure.

9. Data Retention Periods

Personal data is retained only for as long as necessary for the purposes pursued:

• Account data: retained as long as the account is active
• Billing data: retained for 7 years in accordance with legal obligations
• Inactive accounts: deleted after 24 months of inactivity
• Technical data: retained for a limited period for security and analysis purposes

10. Data Security

Swaréy implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk, particularly against:

• Accidental loss or destruction
• Unauthorized access
• Misuse or unauthorized disclosure

11. Users' Rights

In accordance with the GDPR, users have the following rights:

• Right of access to their personal data
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to object
• Right to data portability

Any request can be addressed to: info@swarey.app

A response will be provided within a maximum of one month.

Users also have the right to lodge a complaint with the Data Protection Authority.

12. Data of Minors

The services offered by Swaréy are strictly reserved for persons aged 18 and over.

Swaréy does not knowingly collect or process personal data concerning minors.

Any use of the platform by a minor is prohibited without the legally required authorization.

13. Cookies and Similar Technologies

Swaréy uses:

• Strictly necessary cookies for platform functioning
• Limited and anonymized analytics cookies
• Marketing cookies only with prior user consent when required

14. International Users

The platform primarily targets users located in Belgium, the Netherlands and France.

All personal data is processed in accordance with European GDPR.

15. Changes to this Privacy Policy

Swaréy reserves the right to modify this privacy policy at any time.

The most recent version is always available on the website and in the application.

16. Contact

For any questions about this privacy policy or the processing of personal data, you can contact: info@swarey.app