Welcome to our Privacy Notice. Here we tell you what kind of personal data we collect about you, why we collect it, how we use it and what are your rights regarding your data.
This Privacy Notice applies to individuals who interact with Swappie, including but not limited to:
- Our customer (current and potential)
- Visitor to our website
- A representative or contact person of our corporate customer or business partner
1. Data Controllers
Swappie Oy, Swappie B.V., Swappie Germany GmbH and Eippa WSOperations OÜ (collectively referred to as “Swappie” or “we”) act as joint controllers of your personal data as described in this Privacy Notice. Swappie Oy has been appointed responsible for handling all data subject requests and questions relating to the personal data processing of Swappie on behalf of the local joint controllers. Please note that if Swappie acts as a data processor for its corporate customers or partners, you should refer to privacy notices of those parties for information on the collection and processing of your personal data.
Please also note that Swappie’s website may contain links to other websites. This Privacy Notice applies only to our website. When you click on a link to another website, you will be subject to that website’s privacy policy. We encourage you to review the privacy policies of any website you visit.
2. Personal data collected and processed and sources of data
This section explains what personal data Swappie collects about you and for which purposes, how the personal data is collected, and the legal basis for collecting and processing it. Please note that more than one of the categories below may apply to you (e.g. if you are our customer and you use our website, you should read all the relevant paragraphs). Swappie processes personal data only to the extent necessary and appropriate for the specific processing purpose.
User and usage data
If you interact with us, we may collect the following information about you:
- First and last name
- Identity number or VAT identity number
- Telephone number
- Email address
- Delivery address
- Your payment information e.g. card holder name, number of your payment instrument(s) and the expiration date of your payment instrument(s)
- Demographic data
- Your bank account details if you sell your device to us
- Communications you may have with us
This information is provided by you when you enter into a transaction with us, interact with us (e.g. when you complete our online forms), or communicate with our customer service. We use this information for the purposes of processing your transactions, post purchase services, providing customer service for you, and managing your account in relation to your customership.
Marketing Communications and Campaigns
We may use your personal data for the purposes of providing advertising to you. If you have given us your consent for marketing, e.g. by subscribing to our newsletter, or the law otherwise gives us the right to contact you based on our legitimate interest, we may send you communications and advertisements on our products and services, offers and campaigns, or other relevant news on activities of Swappie or its partners. We may send you these communications via email or SMS, depending on the contact details you have given us. We may also occasionally run campaigns or competitions, where you can provide us with your contact details and possible other information relevant to the specific campaign in connection with your participation. The legal basis for collecting and processing this data is entering into and performing the contract related to the campaign or competition. We use this information for the purposes of carrying out the campaign or competition activities and contacting you regarding your participation. If you wish not to receive our marketing and want to withdraw your consent, you may do it at any time by following the unsubscribe instructions included in our marketing messages or by contacting us directly via the contact details listed below.
Website visits
When you visit our website, we collect information about your device and browsing activity. This information helps us to improve our website, enhance your user experience, and ensure its security. The information we collect may include:
- Your IP address, browser type, operating system, device type, and other technical details. ● Information about how you interact with our website, such as the pages you visit, the links you click, and the time you spend on each page.
- Based on your consent, we use cookies and similar technologies to collect information about your browsing behavior and preferences. You can modify your cookie settings or delete your consent at any time.
- Server logs that record information about your interactions with our website, including access times and error messages.
The legal basis for this processing is our legitimate interest or entering into and performance of a contract between you and us, depending on the situation.
Cookies
We use cookies and similar technologies to collect website usage information. Cookies are pieces of data that websites store on your browser or device when you visit them. When cookies are activated they collect certain personal data about you via your device and browser. The cookies we use may collect the following information:
- IP address
- Browser type, version and session identifiers
- Device type and operating system
- URL trail on the website, time spent and actions on the website
- Time of visit and city-level location
The extent of information listed above that is collected depends on the type of the cookies that are activated. You can choose not to allow the types of cookies that are not strictly necessary for operation of our website via our cookie banner prompted to you when landing on our website. You can also use your browser settings to delete cookies that have already been set at any time.
We use cookies for the following purposes:
- Ensuring our website functions (‘strictly necessary cookies’)
- Providing enhanced functionality and personalisation on our website (‘functional cookies’) ● To provide personalised advertising to you (‘advertising cookies’)
- Measuring, analysing and improving our website’s performance (‘performance cookies’)
Legal basis for collection of the personal data via the cookies is, for strictly necessary cookies, our legitimate interest, or performance of a contract between you and us, depending on the situation. For the rest of the cookies, we rely on the consent you have given us (if you so choose) by clicking accept for the chosen cookies on our cookie banner.
For more detailed information of the cookies currently in use on our website, please refer to the cookies listing at the bottom of this page.
Representatives of our corporate customers / business partners
If you are a representative or contact person of our corporate customer or business partner, or an individual entrepreneur collaborating with us, we collect the following information about you:
- Name and contact details
- Data that is necessary to identify you as our contractual counterparty e.g. proof of identity ● Position and other information about your connection to our customer/business partner ● Possible details about our interactions and your preferences
This information is either provided directly by you when you communicate with us, or, if you are not in direct contact with us first, we receive the data from your organisation and its other representatives we are communicating with. We use this information for the purposes of managing our relationship and executing the contract with the corporate customer / our business partners and communicating in relation to this. The legal basis for data processing is our legitimate interest in relation to managing the contractual relationship and cooperation with the customer or business partner, and additionally, if you are an individual that is our contract counterparty, performance of the agreement between us. If we are obligated to report transactions related to our collaboration to tax authorities we may also need to collect your personal tax identification number and the basis for collection and purpose of processing this data is complying with a legal obligation we are subject to.
Payment service and logistics partners
Please note that when you carry out a payment or payment subscription on our website, your transaction and payment details are submitted to our payment service partner providing the payment function. Similarly, share the details of your order to our logistics partner for the purposes of making the delivery to you or alternatively organising the collection of the product from you. If you are choosing a deferred payment option and therefore applying for credit, our payment service providers may carry out credit checking activities to ensure your creditworthiness. Please refer to the relevant partner’s privacy notice for further info on their data processing activities.
3. Purposes and grounds for collecting and processing personal data
We process personal data only to the extent necessary and appropriate for the specific processing purposes. We may process your personal data based on either for fulfilling a contract between you and Swappie, your consent, or legal obligations (such as fraud prevention and data security purposes) that are binding on us. Part of our functionalities are also based on our legitimate interest to provide our customers with the best possible service experience. Please note that one or more of the following purposes and legal grounds may apply simultaneously.
The performance of a contract
We process your personal data when it is necessary for the performance of a contract to which you are a party to, or to take steps at your request prior to entering into a contract. This includes, but is not limited to, the following purposes:
- To process, manage, and deliver your orders accurately and efficiently, ensuring the smooth execution of our contractual obligations. This includes verifying your identity, confirming your order details, and arranging shipping.
- To handle payments, process refunds, and manage financial transactions related to your orders. This may involve sharing necessary information with payment processors and other service providers to facilitate secure and efficient transactions.
- To communicate with you regarding your order, including confirmations, shipment updates, and any changes to the terms and conditions, privacy policies, or other important updates related to our contractual relationship.
- To respond to your inquiries, resolve support cases, and address any issues arising from our contractual obligations, ensuring that we provide effective customer service. ● To manage subscription services, including subscription renewals, updates, and cancellations
- To provide post-purchase services such as warranty claims, returns, and replacements.
Your consent
In certain aspects of our services, we may request your explicit consent to process your personal data. This typically occurs when the processing is not necessary for the performance of a contract or for compliance with a legal obligation. For example, we may ask for your consent to send you marketing communications. If we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. Withdrawing your consent will not affect the lawfulness of processing based on consent before its withdrawal. To withdraw your consent, please contact us using the contact details provided in the Contact Details section of this policy.
Legitimate interest
We may process your personal data when we have a legitimate interest in doing so, provided that our interests do not override your rights and freedoms. These legitimate interests include running, maintaining, and developing our business operations; improving and personalizing our services, including our website; analyzing and enhancing the customer experience; preventing fraud and ensuring the security of our services; conducting direct marketing and promotional activities, where permitted by law; developing and maintaining customer relationships; analyzing market trends and conducting research; improving and developing our repair and refurbishment services; managing and optimizing our inventory and logistics; and defending or exercising legal claims. When processing your data based on legitimate interests, we carefully balance our interests against your privacy rights, striving to provide you with clear and easy-to-use options to manage
your preferences. You have the right to object to the processing of your personal data based on our legitimate interests. To exercise this right, please contact us using the contact details provided in this Privacy Policy. However, we can refuse such an objection in accordance with applicable legislation.
Legal obligations
We may process your personal data to comply with legal obligations. This includes fulfilling requirements imposed by laws related to taxation, accounting, consumer protection, and other relevant legal frameworks, disclosing your personal data when required by law enforcement agencies, regulatory bodies, or in response to a valid legal process such as a court order or subpoena, and collecting and processing additional identifying information, such as ID copies or numbers, and utilizing fraud prevention technologies to meet our legal obligations and protect our business and customers. This processing is necessary to verify your identity, prevent fraudulent transactions, and comply with anti-money laundering and know-your-customer requirements. We may also share this information with payment service providers and utilize public databases to assess fraud risk, when legally required. Finally, we may retain your personal data for as long as necessary to comply with legal obligations, including statutory retention periods.
4. Data recipients
We share personal data within the Swappie group of companies for the purposes set out above. In addition, in order to fulfil some of the purposes described in this notice, we may share some of your personal data with trusted partners who help us to deliver your orders and improve your experience. These partners include:
- Service providers and commercial partners: We share necessary information with logistics, payment processing, IT service providers, consultants, or our partners participating in your customer journey via collaboration (e.g. our trade-in or drop-off partners) who help us enable the transaction with you.
- Marketing partners: If you have consented to third-party cookies, or subscribed to our newsletters or marketing activities we may share your personal data with these third party cookies providers and our marketing partners that carry out the purpose of processing for us.
We may also disclose personal data to parties outside Swappie if:
- It is required by law, for example in a case where we have to disclose personal data in order to respond to a request made by a public authority or law enforcement agency. ● Disclosing your personal data is necessary to ensure safety and protect the rights of Swappie, our partners, our customers or you, or for the purposes of public interest in accordance with the law.
- We become involved in a merger, acquisition or any form of sale of all or some of our assets, we may share and/or transfer your personal data in connection with the evaluation of and entry into such transactions.
- In any other situation where we have obtained your consent for such transfer.
5. Transfers to countries outside European Economic Area
Swappie stores your personal data primarily within the European Economic Area. However, we have service providers and partners in several geographical locations. As such our service providers and partners may transfer your personal data to, or process it in, jurisdictions outside the European Economic Area or the customers’ domicile. Transfers of this kind are done according to the requirements of the applicable laws, and by following the applicable safeguards for the transfers, e.g. based on adequacy decisions on the level of data protection adopted by European Commission, or using standard contractual clauses approved by European Commission.
6. Storage period
As a general rule, personal data is retained until it is no longer necessary for the purposes described above. The retention terms can be longer if we are under a legal obligation to retain, for example under accounting laws, certain kinds of data in accordance with the retention times set forth in the law. Additionally, if we need to keep any information longer for our legitimate interest of protecting our legal rights we will keep the necessary information for this purpose based on statutes of limitations or, if applicable, until the relevant claim(s) has/have been finally settled.
We apply both technical and organisational measures to keep your personal data secure. We have put in place physical, administrative, and technical security measures to ensure security of processing of your personal data and its confidentiality. Your data can only be accessed by persons for whom it is necessary in relation to their work.
7. Your data protection rights
In accordance with and within the limits of applicable legislation, you have the following rights:
Right to access your personal data – You have the right to know if we are processing your personal data, and to access that data if we are.
Right to correct your personal data – If you consider that any of the personal data we hold about you is inaccurate or incomplete, you can request such personal data to be corrected.
Right to be forgotten – You have the right to request deletion of your personal data, to the extent permitted by law.
Right to restrict processing – In certain situations, you have the right to request restriction of the processing of your personal data.
Right to object processing – In certain situations, you have the right to object to the processing of your personal data.
Right to withdraw your consent – Where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
Right to transfer your personal data – Where legally applicable, you have the right to have the personal data you have provided to us be returned to you in a commonly used, machine-readable format, or, where technically feasible, transferred to a third party.
If you would like to exercise any of these rights, please contact us via the contact information provided at the end of this Privacy Notice. Please note that some of these rights are not absolute and certain limitations may apply when exercising them.
8. Changes to Swappie’s Privacy Notice
We may update this Privacy Notice due to changes in our processing operations or in applicable legislation. When this happens we will make the updated Privacy Notice available here on our website. Therefore, please review this Privacy Notice periodically for any changes.
9. Contact information
If you have any questions about this Privacy Notice, the personal data we hold of you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.
Data controller contact information:
Name: Swappie Oy
Business ID: 2692328-4
Address: Itämerenkatu 3A, 00180 Helsinki, Finland
Email address: privacy (at) swappie.com
Website: www.swappie.com
Should you wish to lodge a complaint or if you feel that Swappie has not addressed your concern in a satisfactory manner, you may contact the competent local supervisory authority of the country of your location, or the supervisory authority of our location, the Finnish Data Protection Ombudsman