PRIVACY POLICY – SWIPEHUB
Last Updated: August 6, 2026
1. Introduction
1.1. SwipeHub is operated by OSKAR ZAJĄCZKOWSKI, an individual entrepreneur / sole proprietor established in Poland (hereinafter "SwipeHub", "we", "us", or "our").
- For any questions, support requests, or legal inquiries, you can contact us at: support@swipehub.my.
1.2. We respect your privacy and are committed to protecting your personal data in accordance with:
- the General Data Protection Regulation (GDPR – EU 2016/679);
- the Polish Act on the Protection of Personal Data;
- the California Consumer Privacy Act (CCPA) – for California residents;
- other applicable global privacy laws.
1.3. For any questions, support requests, or legal inquiries regarding your data, you can contact us at: support@swipehub.my.
2. What Data We Collect
| Category | Data Collected | Purpose |
|---|---|---|
| Account Data | Email address, hashed password, name (optional), email verification status | Create and manage your Account, authenticate you |
| Usage & Diagnostic Logs | Anonymised telemetry (tool invocations, timestamps, HTTP headers, anonymised IP) | Maintain stability, prevent abuse, analyse performance |
| Newsletter Data | Email address, double opt‑in confirmation | Send newsletters (only with your consent) |
| Local Browser Tools | Inputs to non‑AI tools (e.g., JSON Formatter, Base64 Encoder, Password Generator) | Processed entirely locally – no data leaves your device |
| AI Tool Inputs | Prompts sent to AI services via OpenRouter | Processed ephemerally – we do not store your raw prompts or use them to train models |
3. Legal Bases for Processing (GDPR)
3.1. We process your data only when we have a valid legal basis under Article 6 of the GDPR:
| Legal Basis | Examples |
|---|---|
| Contractual necessity (Art. 6(1)(b)) | Creating and managing your Account, providing the Services |
| Legitimate interest (Art. 6(1)(f)) | Security, abuse prevention, performance analysis |
| Consent (Art. 6(1)(a)) | Newsletters, analytics cookies, advertising cookies – consent is voluntary and can be withdrawn at any time |
3.2. You have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
4. Who We Share Data With
4.1. We use only essential third‑party processors to deliver the Services:
| Provider | Purpose | Data Location |
|---|---|---|
| Vercel | Hosting and infrastructure | EU / USA (Data Privacy Framework / SCC) |
| Clever Cloud | PostgreSQL database hosting | EU |
| Apple iCloud Mail / SMTP | Transactional emails & newsletters | EU / USA |
| OpenRouter | AI processing (ephemeral) | No storage – ephemeral processing only |
| Google Analytics 4 | Analytics (with your consent) | EU / USA |
| Microsoft Clarity | Analytics (with your consent) | EU / USA |
| Google AdSense | Advertising (with your consent) | EU / USA |
4.2. All transfers of personal data outside the European Economic Area (EEA) are based on:
- the EU‑US Data Privacy Framework (DPF), or
- Standard Contractual Clauses (SCC) approved by the European Commission.
4.3. We do not sell, rent, or trade your personal data to third parties.
5. Cookies and Similar Technologies
5.1. We use cookies, local storage, and similar technologies for authentication, session management, security, analytics, and advertising.
5.2. The following types of cookies are used:
| Type | Purpose | Consent Required? |
|---|---|---|
| Essential | Authentication, session, security, basic functionality | No – set automatically |
| Analytics | Google Analytics, Microsoft Clarity – performance measurement | Yes – via cookie banner |
| Advertising | Google AdSense – personalised advertisements | Yes – via cookie banner |
| Functional | Remembering user preferences | Yes – via cookie banner |
5.3. You may change your cookie preferences at any time through:
- our consent management panel on the website;
- your browser settings (block or delete cookies).
6. Your Data Protection Rights (GDPR / CCPA)
6.1. Under GDPR and applicable laws, you have the following rights:
| Right | Description |
|---|---|
| Access | Request a copy of the personal data we hold about you |
| Rectification | Correct inaccurate or incomplete data |
| Erasure ("right to be forgotten") | Request deletion of your data |
| Restriction | Restrict processing of your data in certain circumstances |
| Portability | Receive your data in a structured, machine‑readable format |
| Objection | Object to processing for marketing or legitimate interest purposes |
| Withdraw consent | Withdraw consent at any time (e.g., for newsletters) |
| Lodge a complaint | File a complaint with a supervisory authority (e.g., Polish UODO) |
6.2. California residents have additional rights under the CCPA, including the right to:
- know what personal data is collected, used, shared, or sold;
- delete personal data;
- opt‑out of the sale of personal data (we do not sell data).
6.3. To exercise any of these rights, contact us at: support@swipehub.my
6.4. We will respond to your request within 30 days as required by law. Where requests are complex or numerous, we may extend this period by a further 60 days and will inform you of the extension.
7. Data Retention Periods
| Data Category | Retention Period |
|---|---|
| Account Data | Until you delete your Account |
| Usage Logs (anonymised) | Up to 24 months for statistical analysis |
| Newsletter Data | Until you unsubscribe or withdraw consent |
| Security Logs | Up to 12 months |
| AI Tool Inputs | Not stored – processed ephemerally |
7.1. After Account deletion, your data will be removed from active systems within 30 days.
7.2. We may retain certain data for longer periods where:
- required by law (e.g., tax, accounting, or regulatory obligations);
- necessary for the establishment, exercise, or defence of legal claims;
- reasonably required for security, fraud prevention, or backup purposes.
8. Security Measures
8.1. We implement appropriate technical and organisational measures to protect your personal data, including:
- encryption of data at rest and in transit (TLS 1.3);
- restricted access to personal data on a need‑to‑know basis;
- regular security reviews and updates;
- secure authentication mechanisms.
8.2. While we strive to protect your data, no online service can guarantee absolute security. You are responsible for maintaining the security of your own device, browser, and Account credentials.
9. International Data Transfers
9.1. We may transfer your personal data to providers located outside the EEA, primarily to the United States.
9.2. Such transfers are made only on the basis of:
- the EU‑US Data Privacy Framework (DPF) – where the recipient is certified;
- Standard Contractual Clauses (SCC) approved by the European Commission;
- other appropriate safeguards recognised under GDPR.
9.3. You may request a copy of the safeguards used by contacting us at: support@swipehub.my
10. Newsletter and Marketing Communications
10.1. We send newsletters and marketing communications only after explicit, double opt‑in consent.
10.2. You may unsubscribe at any time by:
- clicking the unsubscribe link in every email we send;
- contacting us directly at: support@swipehub.my.
10.3. If you unsubscribe, we will remove your email address from the mailing list within 48 hours.
11. Children's Privacy
11.1. The Services are not directed at children under 16 years of age.
11.2. We do not knowingly collect personal data from minors under 16. If you are a parent or guardian and believe your child has provided us with personal data, please contact us.
11.3. If we learn that we have collected personal data from a child under 16 without verification of parental consent, we will delete that data promptly.
12. Automated Decision-Making and Profiling
12.1. We do not engage in automated decision‑making that produces legal or similarly significant effects on you.
12.2. AI Services may generate recommendations or outputs, but these are based on your inputs and do not constitute automated decisions affecting your legal rights.
13. Changes to this Privacy Policy
13.1. We may update this Privacy Policy from time to time for valid reasons (e.g., legal changes, service evolution).
13.2. For material changes, we will notify you at least 14 days in advance via:
- email to the address associated with your Account;
- a prominent notice on our website.
13.3. The "Last Updated" date at the top of this document indicates the most recent revision.
13.4. Continued use of the Services after changes take effect constitutes acceptance of the updated Privacy Policy.
14. Contact Information
14.1. For any questions, concerns, or requests regarding this Privacy Policy or your personal data:
| Contact Method | Details |
|---|---|
| support@swipehub.my | |
| Operator | Oskar Zajączkowski |
| Country | Poland |
14.2. We will make reasonable efforts to respond to legitimate privacy inquiries within an appropriate timeframe.
15. Governing Law and Dispute Resolution
15.1. This Privacy Policy is governed by Polish law.
15.2. For consumers: Any disputes shall be submitted to the competent courts of your country of residence.
15.3. You also have the right to lodge a complaint with the supervisory authority in your country of residence.
16. Definitions
| Term | Meaning |
|---|---|
| Personal Data | Any information relating to an identified or identifiable natural person |
| Processing | Any operation performed on personal data (collection, storage, use, etc.) |
| Controller | The entity that determines the purposes and means of processing personal data |
| Processor | The entity that processes personal data on behalf of the controller |
| Consent | Freely given, specific, informed, and unambiguous indication of the data subject's wishes |
17. Final Provisions
17.1. If any provision of this Privacy Policy is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.
17.2. The section headings are included solely for convenience and do not affect interpretation.
17.3. By accessing or using the Services, you acknowledge that you have read, understood, and agreed to this Privacy Policy.