This Privacy Policy explains how personal data is collected, used, stored, and disclosed in connection with the SwapX platform available at swapx.gg (the "Platform"). SwapX is an online platform enabling users to exchange and sell in-game digital items. SwapX is not a financial institution, payment service provider, or blockchain operator.
The data controller for the purposes of the GDPR is: ETNERA LTD Neofytou Nikolaidi & Theodorou Kolokotroni, ONISIFOROU CENTER, 2nd floor, Agios Theodoros, 8011, Paphos, Cyprus. Email: privacy@swapx.gg. ETNERA LTD does not appoint a Data Protection Officer, as it is not required under applicable law.
This Privacy Policy applies to all users of the Platform and governs the processing of Personal Data in connection with the use of SwapX services.
This Policy does not apply to third-party platforms or services accessed via the Platform, which are governed by their own privacy policies.
Depending on how you use the Platform, the following categories of Personal Data may be processed:
4.1 Account & Platform Data
4.2 Transaction Data
4.3 Payment Identification Data
Where a user requests a payout via bank transfer or payment card:
This data is collected solely for the purpose of executing payouts via third-party payment service providers.
4.4 Crypto-Related Data
SwapX does not collect private keys or provide custody services.
4.5 Technical Data
4.6 Marketing Communication Data
This data is processed only where the user has explicitly opted in to receive marketing communications. ETNERA LTD does not intentionally collect special categories of personal data.
Personal Data is processed only where permitted by applicable law and solely for the purposes described below:
Personal Data is processed in order to provide and operate the Platform, including user account creation, authentication, and access to SwapX services. The legal basis for this processing is Article 6(1)(b) GDPR (performance of a contract).
Personal Data is processed to execute user-requested transactions, including the exchange and sale of in-game items via the Platform. The legal basis for this processing is Article 6(1)(b) GDPR (performance of a contract).
Where a user requests a payout via a third-party payment provider, Personal Data is processed to enable the execution of such payout. The legal basis for this processing is Article 6(1)(b) GDPR (performance of a contract).
Personal Data may be processed to the extent necessary to comply with legal or regulatory obligations applicable to third-party payment service providers involved in the payout process. The legal basis for this processing is Article 6(1)(c) GDPR (compliance with a legal obligation).
Personal Data is processed to ensure the security, integrity, and proper functioning of the Platform, including fraud prevention, abuse detection, and incident investigation. The legal basis for this processing is Article 6(1)(f) GDPR (legitimate interests).
Personal Data is processed for basic analytics and performance measurement in order to improve the stability, usability, and technical performance of the Platform. The legal basis for this processing is Article 6(1)(f) GDPR (legitimate interests).
Where a user has provided consent, Personal Data may be processed for advertising measurement and campaign attribution purposes using third-party advertising tools. The legal basis for this processing is Article 6(1)(a) GDPR (consent).
Where a user has explicitly opted in, Personal Data may be processed for the purpose of sending marketing communications, including product updates and promotional messages. The legal basis for this processing is Article 6(1)(a) GDPR (consent).
SwapX uses cookies and similar technologies for the following purposes:
Analytics and marketing cookies are used only where required by applicable law and subject to user consent. A separate Cookie Policy applies.
SwapX may use third-party advertising and measurement tools (such as Google Ads or Meta Ads) to measure campaign performance.
Advertising partners may act as independent data controllers with respect to data collected via their technologies.
SwapX does not conduct automated decision-making or profiling within the meaning of the GDPR.
8.1 Service Communications
SwapX may send service-related communications necessary for:
8.2 Marketing Communications
Marketing emails are sent only where a user has explicitly provided prior consent.
Users may withdraw consent at any time via unsubscribe links included in each message.
The Platform integrates with third-party services, including but not limited to:
Such third parties act as independent data controllers or processors, depending on the service provided.
Crypto transactions are processed on public blockchain networks.
ETNERA LTD does not control, verify, or reverse blockchain transactions and is not responsible for blockchain-level errors or failures.
Personal Data is retained only for as long as necessary to:
Payment-related data may be retained for periods required by regulations applicable to payment service providers.
Users have the rights provided under the GDPR, including the right to access, rectify, erase, restrict, or object to the processing of their Personal Data, as well as the right to withdraw consent at any time.
Requests may be submitted to: privacy@swapx.gg
Personal Data may be processed outside the European Economic Area.
Where required, appropriate safeguards are applied in accordance with the GDPR.
ETNERA LTD applies appropriate technical and organizational measures to protect Personal Data. No system can be guaranteed to be fully secure.
ETNERA LTD is not responsible for:
ETNERA LTD may update this Privacy Policy at any time.
Continued use of the Platform constitutes acceptance of the updated Policy.
This Privacy Policy is governed by the laws of the Republic of Cyprus.