Privacy Policy

Date Last Modified: February 17, 2025

  1. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy explains how we collect, use, store, and process your personal data in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We recognise the importance of your privacy and are committed to protecting your personal data when you visit our website, use our services and products, or communicate with us.

For the purposes of UK data protection laws, we act as a Data Controller when determining the purposes and means of processing personal data. In some cases, we may also act as a Data Processor on behalf of a third-party Data Controller.

This Privacy Policy outlines:

  • The legal basis for collecting and processing personal data;
  • The categories of personal data we collect;
  • How and why we process your personal data;
  • Where and for how long we store your data;
  • Who we may share your data with;
  • Your rights under UK data protection law.

We may update this Privacy Policy from time to time, and any changes will be published on our website. We encourage you to review this policy regularly.

By using our services, subscribing to our platform, or submitting information through our website or affiliated applications, you acknowledge that we may collect, process, store, and use your personal data in accordance with this Privacy Policy and other relevant legal documents published on our website.

  1. DEFINITIONS AND INTERPRETATIONS

In this Privacy Policy the following terms shall have the following meanings:

 Company 

means MODIPIK LIMITED, a legal entity registered under the laws of the England and Wales with registration number 16253329, located at 85 Great Portland Street, First Floor, London, England, W1W 7LT, which owns and operates the Website.

 Cookie 

means a small text file placed on your computer or device by our websites when you visit certain parts of the websites. Cookies help enhance user experience, track preferences, and provide analytical insights.

 GDPR 

means the United Kingdom General Data Protection Regulation (UK GDPR), which is derived from the EU General Data Protection Regulation (EU GDPR) 2016/679 and incorporated into UK law through the Data Protection Act 2018 and other relevant legislation.

Data Protection Law

The UK law that supplements UK GDPR, governing the processing of personal data and providing additional data protection rights and obligations.

 

Privacy Policy

Refers to this Privacy Policy, which is updated periodically and published on our website.

 

 Personal Data 

Any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.

 Website 

means the website https://swiftdeals.eu/.

 Services 

means all features, functionalities, content, downloads, tools, resources, information, and assistance offered through the Website or otherwise in connection with it.

 You, Your 

means You, as User, a natural person who is at least 18 years old and agrees to follow this Privacy Policy.

 We, us, our 

refers to the Company.

  1. YOUR DATA PROTECTION RIGHTS

Under the GDPR You, as a data subject, have certain rights over the personal data that We hold and process.

We are committed to make it easy for You to exercise these rights in the most transparent manner possible.

You can exercise any of Your rights in relation to the data that the Company holds about you, by contacting us through the contact details provided in Section 15 (the “Subject Request”). We promise to promptly consider Your request and to respond to You in accordance with the requirements of the Cyprus Data Protection Act and GDPR.

The only exception to the above is the right to erasure (see point d below), which must be submitted exclusively through the support chat available within your account on our website, as specified in Section 15. This procedure provides an additional layer of security to verify your identity due to the permanent and irreversible nature of data deletion.

Response Time and Fees

  • We will respond without undue delay and within one (1) month of receiving your Subject Request.
  • If your request is complex or numerous, we may extend the response time by up to two (2) additional months.
  • Subject Requests are generally free of charge; however, if a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse the request. We will notify you within one (1) month if an extension or fee applies.

 

Your Rights Under UK GDPR:

  1. Right to Be Informed
    You have the right to be informed about how we collect and process your personal data, including the legal basis for processing, categories of data collected, how your data is used, and how long we retain it. This Privacy Policy provides this information, but you can also contact us for further details.
  2. Right of Access
    You have the right to request a copy of the personal data we process about you.
  3. Right to Rectification
    If any personal data we process about you is inaccurate or incomplete, you have the right to request that we correct or complete it.
  4. Right to Erasure ("Right to Be Forgotten")
    You have the right to request the deletion of your personal data. However, this right is not absolute and may be subject to legal obligations that require us to retain your data for a specific period.
  5. Right to Restrict Processing
    You can request that we temporarily suspend processing of your data in certain circumstances (e.g., if you contest the accuracy of the data or object to processing).
  6. Right to Object to Processing
    You may object to us processing your data in certain situations. However, this right depends on the legal basis for processing and may not always apply.
  7. Right to Data Portability
    You have the right to receive your personal data in a structured, commonly used, and machine-readable format and request its transfer to another data controller where:
  • Processing is based on consent or contract; and
  • Processing is carried out by automated means.
  1. Rights Related to Automated Decision-Making and Profiling
    We do not process your personal data in a way that involves automated decision-making or profiling that has legal or significant effects on you.
  2. Right to Lodge a Complaint
    You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) if you believe we have violated your data protection rights. You can contact the ICO as follows:
  • Website: https://ico.org.uk
  • Phone: +44 303 123 1113
  • Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom

 

  1. PERSONAL DATA WE COLLECT ABOUT YOU

During collecting and processing the personal data, the Company adheres the principles as follows:

  • Lawfulness, fairness and transparency

Lawfulness – The Company ensures that there is a valid legal basis for processing personal data, such as consent, contractual necessity, legal obligation, or legitimate interest.

Fairness – The Company ensures that individuals are informed about how their data will be used and that the processing does not have an unjustified adverse impact on them.

Transparency – The Company provides clear and accessible information regarding data processing practices, using plain and straightforward language.

  • Purpose limitation

Personal data is collected for specified, explicit, and legitimate purposes and is not processed in a way that is incompatible with those purposes. Further processing for archiving in the public interest, scientific or historical research, or statistical purposes is permitted under UK law, provided that appropriate safeguards are in place.

Data minimization

The personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

  1. Accuracy

The personal data must be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.

  1. Storage limitation

The personal data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, if only are implemented appropriate technical and organizational measures required by governing law in order to safeguard the rights and freedoms of the data subject.

  1. Integrity and confidentiality

The personal data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

  1. LEGAL BASIS FOR COLLECTING AND PROCESSING PERSONAL DATA

The Company will process Your personal data based on legal bases such as:

Performance of a Contract

  • Processing is necessary for the performance of Our contract with You, including the provision of Our Services and the fulfillment of any contractual obligations.

Legitimate Interests

  • Processing is carried out where it is necessary for Our legitimate business interests, such as:
    • Fraud prevention and security of Our network and services.
    • Improving Our Services and enhancing Your user experience.
    • Ensuring efficient customer support and business operations.
  • Whenever We rely on this legal basis, We conduct a balancing test to ensure that Our business interests do not override Your rights and freedoms. You also have the right to object to processing based on legitimate interests in certain cases.

Consent

  • Where required, We process Your personal data with Your explicit consent, for example, for:
    • Direct marketing communications about Our products and services that may interest You.
  • You have the right to withdraw Your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Legal Obligation

  • We process Your personal data where it is necessary for compliance with legal and regulatory obligations that apply to Us.
  1. CATEGORIES OF THE PERSONAL DATA WE COLLECT

We collect various types of information to provide and improve our services. This may include:

  • User Account Data: login information, username, account preferences, session data, activity logs, clickstream data, usage-related data, profile picture or avatar, steam ID, etc.
  • Contact Information: phone number, email, billing and residence address.
  • Identity Related Data: full name, government-issued identification (ID) number, national ID number, date of birth, details of ID documents, etc.
  • User Identification and Authentication Data: biometrics (e.g., facial recognition or fingerprint data), Multi-Factor Authentication (MFA) data, ID verification documents, etc.
  • Orders and Transactions Data: billing information, order details, payment details, transaction history, current balance, refund information, cancellation data, etc.
  • Financial Data: information about transactions, income and expenses data, current balance, bank account information.
  • Legal and Regulatory Compliance Information: information related to compliance with Anti-Money Laundering (AML), Know Your Customer (KYC) and other similar legal and regulatory requirements, compliance documentation, risk assessment information, sanctions and watchlist screening data, etc.
  • Usage, Technical and Device Data: technical logs and events, information about device type, identifiers and settings, information about operation system, browser-related information, network, and connection information (including IP address), cookies and similar technologies information, etc.
  • Video Surveillance Data: records from video surveillance conducted in our office premises and other related data (e.g., metadata).
  • Marketing Information: communication preferences, your interests, your subscriptions, etc.

 

  1. PROTECTING YOUR PERSONAL DATA AND DATA RETENTION

By accepting this Privacy Policy, You acknowledge and agree to the collection, processing, transfer, and storage of Your personal data under these conditions.

When processing Your personal data under one of the lawful bases specified in this Privacy Policy, We take all reasonable steps to ensure that it is handled securely and in compliance with applicable data protection laws, including the UK GDPR and the Data Protection Act 2018.

The Company implements internationally recognized security standards and adopts physical, technical, and administrative measures to protect Your personal data from loss, misuse, unauthorized access, disclosure, or alteration. These measures include but are not limited to:

  • Access Control – Access to personal data is strictly limited to employees and contractors who require it to perform their duties.
  • Staff Training – Our personnel are trained on data protection policies and procedures, including restrictions on data disclosure and handling.
  • Security Reviews – We conduct regular assessments to ensure compliance with information security policies and regulatory requirements.
  • Technical Safeguards – We use encryption, firewalls, and other security protocols to protect Your personal data from unauthorized access.

All of Our security safeguards are designed to comply with applicable UK laws and regulations, ensuring the confidentiality and integrity of Your personal data.

HOW WE PROTECT YOUR DATA

When You provide Your personal data through Our Website, KYC portals, Our applications, this information is transmitted across the internet securely using industry standard encryption. Your personal data will be held encrypted on secure servers.

Where any third parties processes Your personal data on Our behalf, We require that they have appropriate technical and organizational measures in place to protect this personal data.

HOW YOU CAN PROTECT YOUR PERSONAL DATA

When You create Your account, choose a strong password that is unique to this account. Do not share Your password with other people. Using the same password across Your different accounts will increase the risk of Your data being compromised if Your password is accidentally or unlawfully accessed by unauthorized persons. If You suspect that someone else has got access to Your password, make sure that You change it immediately. Do not share the device containing Your passphrases and keys with friends, family members or even people You trust.

  1. DATA RETENTION

We retain Your personal data only for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, and business requirements.

When determining the retention period for personal data, We consider the following factors:

  • Minimization – We aim to collect and retain only the minimum amount of personal data required for each specific purpose.
  • Purpose of Processing – The nature of the personal data and the specific purpose it serves.
  • Sensitivity – Whether the data includes sensitive or special category personal data.
  • Risk Assessment – The potential risks associated with unauthorized access, misuse, or disclosure, and the security measures in place to mitigate such risks.
  • Legal and Regulatory Obligations – The applicable retention periods mandated by UK laws, including those related to anti-money laundering (AML) and financial regulations.

Your data will be retained as long as Your account remains active. Upon account deletion, We will retain only the personal data necessary to comply with legal, regulatory, and AML obligations. Typically, such data is stored for up to 3 years, unless a longer retention period is required by law.

After the retention period expires, data will be securely archived or permanently deleted in accordance with Our data protection policies, ensuring it remains inaccessible for further processing unless required by law.

  1. THIRD PARTY LINKS

You may find links to third party Websites on Our Website or chats of users contained on Our Website or mobile applications. These Websites should have their own privacy policies which You should check. We do not accept any responsibility or liability for their policies whatsoever as We have no control over them.

  • WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We may disclose any information we collect about You, whether You are a current or former customer, including nonpublic personal information and any other information we collect, to the Company’s affiliated companies and to non-affiliated third parties, which include non-financial companies, such as service providers and fraud verification services.

We may make such disclosures:

  1. to service providers and fraud verification services – KYC/AML services providers that perform services on Our behalf provided that there’s a non-disclosure agreement with such service providers; and
  2. to marketing services, agencies and other service providers – for everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus;
  3. to legal / state authorities and authorized services – if we are under a duty to disclose or share Your information to comply with Our legal obligations.

We will share information with companies, organizations or individuals outside of the Company and/or to other parties which are not stated in this Privacy Policy when We have Your explicit consent.

We may share information in response to a request for information if We believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request, including, but not limited to, meeting national security or law enforcement requirements. To the extent the law allows it, We will attempt to provide You with prior notice before disclosing Your information in response to such a request.

We may share information if We believe that it's necessary to protect the vital interests of the data subject (i.e. to prevent imminent serious physical harm or death to a person.)

We may share information if We believe Your actions are inconsistent with Our user agreements, rules, or other Company policies, or to protect the rights, property, and safety of ourselves and others.

We may share information between and among the Company and any of Our parents, affiliates, subsidiaries, and other companies under common control and ownership.

We may share information with vendors, consultants, and other service providers (but not with advertisers and ad partners) who need access to such information to carry out processing activities for us. The partner’s use of personal data will be subject to appropriate confidentiality and security measures.

We may share Your private personal data with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use Your private personal data only on Our behalf and pursuant to Our instructions.

We may share Your private personal data with Our partners to make a transaction.

Where any third parties process Your personal data on Our behalf, We require that they have appropriate technical and organizational measures in place to protect this personal data and We will also ensure that they are GDPR compliant. Data Processing Agreement is in place between the Company and the third party so that both parties understand their responsibilities and liabilities pursuant to GDPR.

  1. INTERNATIONAL TRANSFERS OF PERSONAL DATA

The UK GDPR applies to controllers and processors located in the United Kingdom (UK), the European Economic Area (EEA), and countries that the UK government has deemed to provide adequate levels of data protection.

If personal data is transferred outside of:
i) the UK or EEA, or
ii) countries that hold adequacy status under UK data protection law,

such transfers are restricted unless appropriate safeguards are in place to protect the rights of data subjects, or an exemption applies (e.g., Your explicit and informed consent).

The Company will not transfer Your personal data outside the UK, EEA, or an adequacy-approved country unless:

  • You have provided explicit and informed consent, or
  • Appropriate safeguards (such as Standard Contractual Clauses or Binding Corporate Rules) are in place, or
  • The transfer falls under a recognized exception in compliance with UK GDPR.

We take all necessary measures to ensure that any cross-border transfers of personal data comply with applicable UK laws and maintain the security of Your data.

  1. ADVERTISING, ANALYTICS AND BUSINESS PARTNERS (LIMITED TO NON-PERSONALLY IDENTIFIABLE INFORMATION)

We may share aggregated or pseudonymous information (including demographic information) with partners, such as publishers, advertisers, measurement analytics, apps, or other companies. We do not share information that personally identifies You (personally identifiable information is information like name or email address) with these partners, such as publishers, advertisers, measurement analytics, apps, or other companies.

  1. OTHER INFORMATION

The Company may collect and process non-personal data that does not directly identify You as an individual (e.g., usage patterns, anonymized statistics). This data is the exclusive property of the Company, and We may use it at Our discretion for operational, analytical, or business improvement purposes.

We may share aggregated and anonymized statistical data with third parties (e.g., the number of registered users, website traffic volume, and patterns). However, this data will never identify You personally.

The Company will not use Your email address or other contact details for marketing or commercial purposes without Your explicit consent.

Additionally, if You contact Us, We may retain Your messages for the purpose of handling Your inquiry and improving Our services. However, We will not share the content of these messages with third parties unless required by law.

  1. USE OF COOKIES

To enhance the quality of Our services, provide You with relevant content, and better understand how You use Our Website and applications, We use technologies such as Cookies. Cookies do not typically contain information that directly identifies You. However, personal information that We store about You may be linked to the data collected through Cookies.

We use Strictly Necessary Cookies, which are essential for the operation of Our Website. These include:

User session key – A temporary key issued to You after successful login, enabling session management.

Browser language – Used to optimize language preferences for Your browsing experience.

These Cookies are required to enable secure access to certain areas of Our Website and ensure proper functionality. Since these Cookies are essential for Our Website's operation, they do not require Your consent.More information about use of cookies: Cookie Policy

  1. CONTACTING US

In compliance with GDPR, We commit to resolve complaints about Our collection or use of Your personal information.

We welcome any queries, comments or requests You may have regarding this Privacy Policy. If You wish to make any GDPR Subject Request or to receive any other relevant information,, please do not hesitate to contact Us via info@swiftdeals.eu.