Privacy policy of Swap

Effective Date: 01/01/2025 | Last Updated: 18/09/2025

1. Introduction

Welcome to Swap ("we," "our," or "us"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and platform (the "Service").

By accessing Swap, you agree to the collection and use of information in accordance with this policy. Given the nature of financial services, disagreeing with these terms will prevent you from using our trading and withdrawal features.

2. Information We Collect

2.1 Information You Provide to Us

a. Personal Identity (KYC):

• Full name, date of birth, and gender

• Government-issued ID (e.g., BVN, NIN, or International Passport) for identity verification

• Live "selfie" photos for biometric verification

b. Financial & Contact Information:

• Email address and phone number

• Nigerian bank account details (for NGN withdrawals)

• External crypto wallet addresses and transaction hashes

• Gift card images and claim codes provided for trade

2.2 Information Automatically Collected

c. Technical & Transaction Data:

• Device information (IP address, device ID, and operating system)

• Geo-location data (to prevent fraudulent logins from unauthorized regions)

• Detailed logs of all swaps, trades, and withdrawal history

3. How We Use Your Information

We use the collected data to:

• Verify your identity and comply with Anti-Money Laundering (AML) regulations

• Facilitate the swapping of crypto assets and the liquidation of gift cards

• Process instant NGN withdrawals to your linked Nigerian bank accounts

• Protect your account from unauthorized access and fraudulent activities

• Provide real-time support for your trades and transactions

• Improve our exchange rates and platform performance

• Comply with legal obligations from financial regulatory bodies

4. Information Sharing and Disclosure

4.1 With Financial Partners

a. We share necessary bank details with our payment gateway partners to process your NGN withdrawals.

b. Identity data is shared with licensed KYC providers (such as SmileID or similar) to verify your documents.

4.2 Legal Requirements

c. We may disclose your information to the Central Bank of Nigeria (CBN) or other law enforcement agencies if required by law or to prevent financial crimes.

4.3 Business Transfers

d. In the event of a merger or acquisition, your transaction history and profile may be transferred as a core business asset.

5. Data Security

Swap employs military-grade encryption and security protocols:

• AES-256 encryption for sensitive data at rest

• Two-Factor Authentication (2FA) for all withdrawals and sensitive account changes

• Secure Socket Layer (SSL) technology for all data in transit

• Regular audits of our smart contracts and wallet infrastructure

Please note that while we secure our platform, you are responsible for keeping your login credentials and private keys/seed phrases confidential.

6. Your Rights and Choices

6.1 Access and Update

a. You can update your bank details and contact info within the app settings.

6.2 Account Closure

b. You may request to deactivate your account. However, due to financial regulations, transaction logs must be retained for a statutory period.

6.3 Data Portability

c. You may request a summary of your transaction history for personal record-keeping.

7. Data Retention

As a financial service provider, Swap is legally required to retain your KYC and transaction data for a minimum period (typically 5–7 years) even after account closure. This is to comply with global AML (Anti-Money Laundering) and Counter-Terrorism Financing (CTF) laws.

8. International Operations

While Swap primarily serves the Nigerian market, our data may be processed on secure global cloud servers (like AWS or Google Cloud). By using the service, you consent to this cross-border data processing in line with international security standards.

9. Children's Privacy

Swap is strictly for individuals aged 18 and above. We do not permit minors to trade crypto or sell gift cards on our platform. If we discover a minor has bypassed our KYC, the account will be terminated immediately.

10. Changes to This Privacy Policy

We may update this policy to reflect changes in crypto regulations. We will notify you via app notifications or email when significant changes occur.

11. Contact Us

For privacy-related inquiries or to report suspicious activity, contact us at:

Swap Digital Technologies

Email: privacy@swap.app

Lagos, Nigeria

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