Privacy Policy | SwiftGrowth

This Privacy Policy explains how SWIFTWARE.IO LTD ("SwiftGrowth," "we," "us," or "our") collects, uses, and shares information about you when you use our conversation-led growth platform, including our websites, web application, APIs, and related services (collectively, the "Service").

This Privacy Policy is intended as a general information notice and does not constitute legal advice. Privacy laws vary by jurisdiction. You are responsible for ensuring that your use of SwiftGrowth complies with all laws and regulations that apply to you and to your customers, including obtaining any required consents. You should review this Policy with qualified legal counsel before relying on it for your own compliance.

1. Who we are and how to contact us

The Service is provided by SWIFTWARE.IO LTD, a company incorporated in the United Kingdom and located in London. If your actual registered details (including company number and registered office address) differ from this description, you must update this section and all references accordingly before publishing this Policy.

For privacy-related questions or requests, you can reach us at: privacy@swiftware.io (replace this email address and add your full registered office address and company number as appropriate for your legal entity).

2. Scope and roles

This Privacy Policy applies to information we process about:

Workspace owners and team members who create and manage SwiftGrowth accounts.
End customers who communicate with our customers through channels such as WhatsApp, Instagram, Messenger, email, or web chat.
Website visitors who browse our marketing pages.

When we process information about your customers on your behalf (for example, conversation histories, contact profiles, and campaign data), we generally act as a "processor" or "service provider" under data protection laws. You (the workspace owner or organization) are the "controller" or "business" for that data and are responsible for providing your own privacy notices to your end customers and obtaining any necessary consents.

3. Information we collect

3.1 Information you provide to us

Account and workspace information, such as your name, email address, password (hashed), organization name, role, and settings.
Billing information, such as subscription plans and payment-related details processed via third-party payment providers (e.g., Stripe). We do not store full payment card numbers.
Customer contact data that you import or collect through the Service, including names, phone numbers, email addresses, social media identifiers, tags, and custom fields.
Conversation content including messages, attachments, AI-generated responses, notes, and metadata across WhatsApp, Instagram, Messenger, email, web chat, and other integrated channels.
Support and feedback information when you contact us for help or provide feedback about the Service.

3.2 Information we collect automatically

Usage data, such as log data, device and browser type, operating system, IP address, timestamps, pages viewed, and features used.
Performance and analytics data to understand how the Service is used, improve reliability, and detect abuse.

3.3 Cookies and similar technologies

We and our service providers may use cookies and similar technologies (such as pixels and local storage) to:

Remember your preferences and keep you signed in.
Measure how visitors interact with our marketing site and product.
Secure the Service and prevent fraud or abuse.

Depending on your jurisdiction, certain cookies (for example, analytics or advertising cookies) may require your consent. If you operate your own tracking scripts or embed third-party tools through SwiftGrowth, you are responsible for implementing any cookie consent or disclosure mechanisms required by law.

4. How we use information

We use the information we collect for the following purposes:

Providing and maintaining the Service, including routing and delivering messages, managing contacts and workspaces, and powering the unified inbox, broadcasts, analytics, and AI features.
AI-powered automation, such as generating suggested or automated responses, classifying conversations, and assisting agents, using third-party AI models (for example, OpenAI).
Customer support, including responding to your inquiries and resolving technical issues.
Improving and securing the Service, including monitoring usage, debugging, preventing fraud and abuse, and developing new features.
Communicating with you about updates, security alerts, and administrative messages related to your account or the Service.
Marketing, where permitted by law, such as sending you information about new features, offers, or surveys. You can opt out of marketing communications at any time.
Legal and compliance purposes, including enforcing our Terms of Service, complying with applicable laws, and protecting the rights, safety, and property of SwiftGrowth, our customers, and others.

5. Legal bases for processing (EEA, UK and similar jurisdictions)

Where applicable data protection law (such as the EU/UK GDPR) requires a legal basis, we rely on the following:

Performance of a contract when we provide the Service to you or your organization.
Legitimate interests, such as improving and securing the Service, preventing fraud, and communicating with you about your account and important updates, provided that these interests are not overridden by your rights and interests.
Consent, where required by law (for example, certain marketing or cookie uses). When we rely on consent, you may withdraw it at any time.
Compliance with legal obligations, such as maintaining records for tax or regulatory purposes.

6. How we share information

We share information as necessary to operate the Service and as described below:

Service providers and subprocessors who support our infrastructure and product, such as cloud hosting providers (e.g., Supabase, Vercel or similar), database, logging and monitoring tools, email delivery services, and customer support tools.
AI and analytics providers that process conversation data and usage data on our behalf to generate responses, classify conversations, and provide analytics. These providers act as our processors and are contractually restricted from using your data for their own advertising purposes.
Messaging and social platforms such as Meta platforms (WhatsApp Business, Instagram, Messenger) and email providers, to send and receive messages as directed by you. Your use of these channels is also subject to their own terms and privacy policies.
Payment processors (such as Stripe) that handle billing and payments on our behalf.
Professional advisors (such as lawyers, auditors, and consultants) where reasonably necessary for the management of our business.
Business transfers in connection with a merger, acquisition, financing, reorganization, or sale of assets involving SwiftGrowth, subject to appropriate confidentiality protections.
Legal and safety disclosures when we believe in good faith that disclosure is reasonably necessary to comply with law, respond to valid legal process, or protect the rights, property, or safety of SwiftGrowth, our users, or the public.

We do not sell personal information in the traditional sense of the word. If you are subject to CCPA/CPRA or similar laws and consider certain sharing to be a "sale" or "sharing for cross-context behavioral advertising," you should consult legal counsel to configure your own notices and opt-out mechanisms as required.

7. International data transfers

We may process and store information in countries other than the country where you are located. Where required by law, we implement appropriate safeguards for international transfers, such as standard contractual clauses for transfers from the EEA, UK, or Switzerland. You are responsible for ensuring that your use of the Service in connection with your own customers complies with any local transfer restrictions that apply to you.

8. Data retention

We retain personal information for as long as reasonably necessary to provide the Service, comply with our legal obligations, resolve disputes, and enforce our agreements. Retention periods may depend on your workspace settings and the nature of the data (for example, conversation histories, contact records, and analytics data). You may be able to configure certain retention settings or delete data from within your workspace.

9. Your rights and choices (including GDPR/CCPA rights)

Depending on your location and applicable law, you may have certain rights with respect to your personal information, such as:

Accessing, correcting, or updating your information.
Requesting deletion of your information, subject to legal limitations.
Objecting to or restricting our processing of your information in certain circumstances.
Receiving a copy of your information in a portable format.
Withdrawing consent where we rely on your consent to process information.

If we process your information as a processor on behalf of a customer, we may redirect your request to that customer (the controller) where appropriate. You or your end users can exercise applicable rights by contacting us at the email address listed above.

10. Security

We use reasonable technical and organizational measures designed to protect personal information against unauthorized access, loss, misuse, or alteration, including encryption in transit, access controls, and logical separation between organizations. However, no system can be guaranteed to be 100% secure, and you are responsible for maintaining the security of your login credentials and for configuring workspace-level permissions appropriately.

11. Children's privacy

The Service is not directed to children under 16, and we do not knowingly collect personal information from children under 16. If you believe that a child has provided us with personal information in violation of this Policy, please contact us so that we can take appropriate steps to delete such information.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date at the top of the Policy and, where appropriate, provide additional notice (such as by email to workspace owners or in-app notifications). Your continued use of the Service after any changes become effective signifies your acceptance of the updated Policy.

13. How to contact us

If you have any questions or concerns about this Privacy Policy or our data practices, you can contact us at the email address noted above. You may also have the right to lodge a complaint with a data protection authority in your country or region. You should consult your legal counsel to determine which supervisory authority is appropriate for your circumstances.

This Privacy Policy template is provided for informational purposes only and does not constitute legal advice. You are solely responsible for reviewing, customizing, and implementing a privacy notice that meets your specific legal obligations.

For additional terms governing your use of SwiftGrowth, please also review our Terms of Service.