PRIVACY POLICY

Effective date: 29 August 2026

1. Who We Are

Swifty.gg is operated by Individual Entrepreneur Primo Support, identification number 305799017, registered at Georgia, Tbilisi, Krtsanisi District, Nikoloz Baratashvili Street N12 / Sanapiro Street N2, Floor 2.

Contact: pr@swifty.gg

In this Privacy Policy, “Swifty,” “we,” “us,” and “our” refer to Individual Entrepreneur Primo Support.

Swifty is the controller of personal data for which it determines the purposes and means of processing.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal data when you visit or use Swifty.gg.

2. Scope

This Privacy Policy applies when you:

visit Swifty.gg;
authenticate through Steam;
connect your Steam profile or inventory;
request an Offer;
submit or complete an Order;
communicate through live chat or email;
use a promo or affiliate code;
subscribe to promotional communications; or
otherwise interact with Swifty.

A third-party service may have its own privacy policy where it independently determines how and why it processes your information.

3. Information We Process

3.1 Steam and Account Information

We may process:

Steam ID;
Steam display name;
avatar;
public profile information;
public inventory information;
Trade URL or trade token;
Item and inventory identifiers;
account and trade eligibility;
Steam restrictions;
authentication and connection timestamps; and
Swifty Account status.

Swifty does not require your Steam password, Steam Guard code, recovery code, or Steam API key.

3.2 Item and Order Information

We may process:

Item asset identifiers;
Item name, type, condition, float, pattern, stickers, and similar characteristics;
Offer and Accepted Amount information;
Order identifiers;
selected Items;
promotional adjustments;
trade-offer identifiers;
trade status;
Trade Protection status;
payout status;
cancellation or reversal information;
transaction timestamps; and
records needed to establish whether an Order was completed.

3.3 Transaction Provider Information

Payout destination information is normally entered directly into a Transaction Provider’s interface.

Swifty does not ordinarily receive or store the complete payout destination or complete account credentials collected directly by the Transaction Provider.

Swifty may receive limited information such as:

the provider used;
a provider transaction reference;
the payout amount;
transaction status;
completion time;
rejection or failure reason;
masked or partial destination information;
eligibility or security status; and
dispute or reversal status.

A Transaction Provider may process information under its own privacy policy and legal obligations.

3.4 Technical and Security Information

We may process:

IP address;
browser type and version;
device type;
operating system;
language;
time zone;
approximate location derived from IP address;
referring page;
pages viewed;
session identifiers;
authentication events;
error and diagnostic information;
security logs;
fraud and abuse signals; and
cookie or similar technology identifiers.

3.5 Communications

If you contact us, we may process:

your email address;
live-chat messages;
support emails;
complaint or enquiry details;
files or screenshots you voluntarily provide;
communication timestamps; and
information necessary to resolve the request.

Do not send passwords, authentication codes, API keys, recovery codes, or unnecessary identity documents through email or live chat.

3.6 Promotions, Affiliates, and Marketing

Where applicable, we may process:

promo codes;
affiliate or referral identifiers;
campaign information;
attributed transaction status;
reward or commission status;
email address;
marketing preferences; and
records of consent and withdrawal.

We do not provide affiliates with your complete payout information merely because they referred you.

4. Where Information Comes From

We may obtain personal data:

1.Directly from you.
2.From Steam through authentication, public profiles, inventories, and trading functions.
3.From Transaction Providers.
4.Automatically through website logs, cookies, and similar technologies.
5.From an affiliate or referring partner.
6.From security, hosting, support, or technical service providers.
7.From public sources where use of that information is lawful.

Publicly visible Steam information may still be personal data when it can be connected to an identifiable user.

5. Why We Use Personal Data

We process personal data for the following purposes.

Providing the Service and Performing Our Contract

We use information to:

authenticate users through Steam;
display eligible Items;
calculate Offers;
receive and administer Orders;
verify Item transfers;
monitor Trade Protection status;
arrange payouts;
send transaction confirmations;
correct errors;
return Items where necessary; and
provide support.

The legal basis is taking steps at your request before entering into a contract and performing our contract with you.

Some information is required to process an Order. If you do not provide the necessary information, we may be unable to provide the relevant part of the Service.

Security and Fraud Prevention

We use information to:

secure Accounts and systems;
identify unusual activity;
detect stolen or disputed Items;
prevent account compromise;
prevent promo and affiliate abuse;
investigate reversals and disputes;
enforce our Terms; and
establish, exercise, or defend legal claims.

The legal basis is our legitimate interest in protecting Swifty, users, Transaction Providers, and the integrity of the Service, as well as contract performance and compliance with legal obligations where applicable.

Legal and Accounting Obligations

We may process and retain information to:

maintain transaction and accounting records;
comply with tax obligations;
respond to lawful authority requests;
comply with court orders;
respond to data-protection requests; and
meet other legal requirements.

The legal basis is compliance with applicable law.

Service Operation and Improvement

We may use limited technical and usage information to:

diagnose errors;
monitor performance;
prevent outages;
improve transaction flows;
measure feature usage; and
develop the Service.

The legal basis may be our legitimate interests or your consent, depending on the technology used and applicable law.

Marketing

We use your email address to send newsletters or promotional communications only where you have provided the required separate consent.

You may withdraw consent at any time.

6. Automated Systems

Swifty may use automated systems to calculate Offers based primarily on Item characteristics, market information, liquidity, demand, Steam restrictions, operational costs, and inventory requirements.

We may also use automated security signals to identify suspicious activity.

These systems are not intended to make decisions based on sensitive personal characteristics.

You may contact pr@swifty.gg if you believe an automated restriction or decision concerning your Account or Order is incorrect.

7. How We Share Information

We may share personal data with the following categories of recipients.

Transaction and Inventory Providers

We may share information needed to:

receive or hold Items;
process payouts;
confirm transaction status;
detect fraud;
resolve failed transactions; and
investigate disputes.

A provider may act as our processor or as an independent controller for its own services and legal obligations.

Steam

Information is exchanged with Steam as necessary for authentication, inventory access, trade creation, Item transfer, restriction status, and trade records.

Steam processes information under its own terms and privacy policy.

Technology and Operational Providers

We may use providers for:

website hosting;
cloud infrastructure;
security and fraud prevention;
databases;
email delivery;
customer support and live chat;
error monitoring;
analytics;
consent management; and
affiliate attribution.

Providers processing information on our behalf are expected to use it only for the agreed purposes and to apply appropriate confidentiality and security measures.

Affiliates

We may share limited referral or attribution information needed to confirm whether an eligible referral occurred and calculate an affiliate commission.

We do not disclose complete payout details, unnecessary Item history, or unrelated Account information to affiliates.

Professional Advisers and Authorities

We may disclose information to lawyers, accountants, auditors, insurers, courts, regulators, law-enforcement bodies, or other competent authorities where reasonably necessary or legally required.

Business Transfers

Information may be transferred as part of a genuine merger, restructuring, financing, acquisition, insolvency process, or sale of all or part of the Service.

Any recipient must process the information in accordance with applicable law.

8. Sale of Personal Data

Swifty does not sell personal data to data brokers or other parties for monetary consideration.

We do not sell users’ payout information or Item-sale history.

9. International Processing

Swifty operates from Georgia, while Steam, Transaction Providers, hosting providers, live-chat providers, email services, and other service providers may process information in other countries.

Where personal data is transferred internationally, we seek to use an appropriate legal basis and reasonable contractual, organisational, and technical safeguards.

The level of legal protection may differ between countries.

You may contact pr@swifty.gg for additional information about a relevant transfer.

10. Retention

We keep personal data only for as long as reasonably necessary for the purpose for which it was collected, legal obligations, security, dispute resolution, and the establishment or defence of legal claims.

In general:

Order, transaction, and accounting records may be retained for six years after the end of the relevant accounting period.
Account connection information may be retained while the Account remains active and for a reasonable period after closure or inactivity.
Support communications may generally be retained for up to two years after the matter is resolved.
Technical and security logs may generally be retained for up to twelve months, unless needed for an investigation or dispute.
Marketing information is retained until you withdraw consent or the marketing activity ends.
Records showing marketing consent or withdrawal may be retained for the duration of the marketing activity and for one year after it ends.
Cookie information is retained for the period described in the Cookie Policy or Cookie Settings.

Information may be retained longer where required by law, a court order, an unresolved dispute, a fraud investigation, or a security incident.

When information is no longer needed, it will be deleted, anonymised, or securely isolated.

A Transaction Provider may have its own retention period for information it processes independently.

11. Cookies

Swifty may use cookies and similar technologies for security, authentication, transaction progress, preferences, analytics, affiliate attribution, live chat, and marketing.

Strictly necessary technologies may be used without optional consent where legally permitted.

Optional analytics, advertising, or marketing technologies will be activated only after the consent required by applicable law.

More information is available in our Cookie Policy.

12. Marketing Choices

Marketing consent is separate from acceptance of the Terms of Service.

You may unsubscribe by:

using the unsubscribe link in a promotional email; or
contacting pr@swifty.gg.

Withdrawal is free of charge.

We will stop promotional communications within the period required by applicable law.

We may retain limited suppression information to ensure that you are not accidentally subscribed again without a valid legal basis.

Service communications concerning Orders, security, support, policy changes, or Account operation are not promotional communications.

13. Security

We use reasonable technical and organisational measures intended to protect personal data, including measures such as:

encrypted transmission;
access controls;
restricted administrative permissions;
system monitoring;
security logging;
software updates;
provider due diligence;
backup and recovery controls; and
incident-response procedures.

No online service can guarantee absolute security.

You are also responsible for protecting your Steam account, devices, and authentication methods.

14. Your Rights

Depending on applicable law, you may have the right to:

receive information about how your personal data is processed;
access your personal data;
obtain a copy of your personal data;
correct inaccurate or incomplete information;
request deletion or destruction;
request restriction or blocking;
object to certain processing;
withdraw consent;
object to direct marketing;
request data portability where applicable;
challenge certain automated decisions where applicable; and
lodge a complaint with a competent data-protection authority or court.

To exercise a right, contact pr@swifty.gg.

We may request reasonable information to confirm your identity before completing the request.

A deletion request does not require us to delete information that must be retained for an accepted transaction, accounting, fraud prevention, security, a legal claim, or another lawful purpose.

Withdrawing consent does not affect processing that was lawful before withdrawal or processing supported by another legal basis.

15. Minors

The Service is intended only for users aged 18 or older.

Swifty does not knowingly permit minors to sell Items through the Service.

If we learn that a minor has used the Service in violation of the Terms, we may restrict the Account and delete or otherwise lawfully handle the relevant information.

16. Third-Party Links and Services

Swifty may link or redirect to Steam, Transaction Providers, live-chat systems, or other third-party services.

Those parties may independently collect and process personal data under their own privacy policies.

Swifty is not responsible for an independent third party’s privacy practices.

17. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in law, technology, providers, or the Service.

The updated version will display a new effective date.

Where a material change affects how we use personal data, we may provide additional notice or request consent where required.

18. Contact

Data controller:

Individual Entrepreneur Primo Support
Identification number: 305799017
Address: Georgia, Tbilisi, Krtsanisi District, Nikoloz Baratashvili Street N12 / Sanapiro Street N2, Floor 2
Email: pr@swifty.gg