Privacy Policy Welcome to Safe Swap and our website at www.safeswapja.com (our “website”). At Safe Swap, we are committed to protecting and respecting your privacy. This privacy policy sets out the basis on which we will process any Personal Data that we may collect about you as a visitor to our website. This policy further sets out how we protect your privacy and your rights in respect of our use of your Personal Data. WHAT IS PERSONAL DATA? Personal Data is information that makes it possible to identify a natural person. This includes, in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data exists if no personal reference to the user can be made. WHAT IS PROCESSING? "Processing" means and covers virtually any handling of data. WHAT LAW APPLIES? We will only use your Personal Data in accordance with the UK`s Data Protection Act (“DPA”) and the EU's General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy. WHO IS RESPONSIBLE FOR DATA PROCESSING? The responsible party within the meaning of the above is Safe Swap of [Insert PO Box], Kingston, Jamaica (“Safe Swap”, “we”, “us”, “our”). If you want to contact us or if you have any questions, you can reach us by email using safeswapja@gmail.com. WHAT ARE THE LEGAL BASES FOR PROCESSING PERSONAL DATA In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent; b) the data is necessary for the fulfilment of a contract/pre-contractual measures; c) the data is necessary for the fulfilment of a legal obligation; or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden. WHAT PERSONAL DATA DO WE COLLECT FROM YOU? We may collect and process the following Personal Data about you: a) Personal Data that you give us: This is information about you that you give to us by filling in forms on our website or correspond with us by telephone, post, email, or when you create a user account or otherwise. It may include, for example, your name, address, email address, and telephone number; information about your business relationship with us; and information about your requirements and interests. We also process the Personal Data involved in your use of our escrow services (your contact information, such as your full name, email, postal address, and phone number, and the data related to your use of our services and the contract between us) in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of your consent, fulfilling our contractual obligations and our legal obligations. b) Personal Data that our website and other systems collect about you: If you visit our website, it will automatically collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information, such as the pages on our site that you visit. This is used to monitor the performance of the website and improve the experience of visitors to the website. Privacy Policy We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. As set out in the DPA and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of non-essential cookies. For further information on the cookies we use, please refer to our Cookie Policy. c) Other information: For business reasons, we analyze the data we have on web and server traffic patterns, website interactions, browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and/or anonymized values (“Aggregated Data”). Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.For this purpose we use Google Analytics from Google. The legal basis is our legitimate interest and your consent. For further information on our use of Google Analytics, please refer to our Cookie Policy. DATA PROCESSING THROUGH THIRD-PARTY SERVICES We use the content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services ("Content") on our website. This always requires that the third-party providers of this Content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content. The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called optout measures, if any: a) Hosting: Namecheap; b) Analytics: Google Analytics from Google; and c) Spam Protection: reCAPTCHA from Google HOW WILL WE USE YOUR PERSONAL DATA? We may collect, store, and use your Personal Data for the following purposes: ● to operate, manage, develop, and promote our business and, in particular, our relationship with you and related transactions, including, for example: ○ marketing purposes (when we have either gathered prior opt-in consent and/or have a legitimate interest to send you communications which we believe to be relevant and of use to you); ○ accounting and billing/payment purposes; ○ to operate, administer, and improve our website and other aspects of the way in which we conduct our operations; ○ to offer you our services; ○ to provide you with services or information that you may have requested; and ○ to keep you informed and updated on relevant topics or services you may be interested in. ● to protect our business from fraud, money laundering, breach of confidence, theft of proprietary materials, and other financial or business crimes; ● to comply with our legal and regulatory obligations, bring and defend legal claims and assert legal rights; and ● if the purpose is directly connected with an assigned purpose previously made known to you. We will only process your Personal Data as necessary so that we can pursue the purposes described above and where we have a legal basis for such processing. Where our lawful basis for processing is that such processing is necessary to pursue our legitimate interests, we will only process your Personal Data where we have concluded that our processing does not prejudice you or your privacy in a way that Privacy Policy would override our legitimate interest. In exceptional circumstances, we may also be required by law to disclose or otherwise process your Personal Data. DATA SHARING In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients. a) Internal If necessary, we transfer your Personal Data within Safe Swap. Access to your Personal Data is only granted to authorised employees who need access to the data due to their job, e.g., to provide our services or to contact you in case of queries. b) External bodies Personal Data is transferred to our service providers in the following instances: ● in the context of fulfilling our contract with you, ● to use marketing services and to advertise our services online, ● to communicate with you, ● to provide our website, and ● to state authorities and institutions as far as this is required or necessary. c) International transfers We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer. HOW LONG DO WE KEEP YOUR PERSONAL DATA? We will delete your Personal Data when we no longer need such Personal Data, for instance where: ● it is no longer necessary for us to retain your Personal Data to fulfil the purposes for which we had collected it; ● we believe that your Personal Data that we hold is inaccurate; or ● in certain cases where you have informed us that you no longer consent to our processing of your Personal Data. Sometimes, however, there are legal or regulatory requirements which may require us to retain your Personal Data for a specified period, and in such cases we will retain your Personal Data for such specified period; and we may need to retain your Personal Data for certain longer periods in relation to legal disputes, and in such cases we will retain it for such longer periods to the extent required. DATA SECURITY Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through our website. YOUR RIGHTS AND PRIVILEGES a) Privacy rights You can exercise the following rights under the DPA and the GDPR: ● The right to access; ● The right to rectification; Privacy Policy ● The right to erasure; ● The right to restrict processing; ● The right to object to processing; ● The right to data portability; b) Updating your information and withdrawing your consent If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us. c) Access Request In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why. d) Complaint to a supervisory authority You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Jamaica is the Office of the Information Commissioner (OIC) (www.oic.gov.jm). We would, however, appreciate the chance to deal with your concerns before you approach the OIC. e) What we do not do ● We do not request Personal Data from minors and children; ● We do not process special category data without obtaining prior specific consent; ● We do not use Automated decision-making including profiling; and ● We do not sell your Personal Data. HELP AND COMPLAINTS If you have any questions about this policy or the information we hold about you, please contact us by email using safeswapja@gmail.com. CHANGES The first version of this policy was issued on Sunday, 6th of October, 2024, and is the current version. Any prior versions are invalid, and if we make changes to this policy, we will revise the effective date.