Smart Tech Support Limited (hereinafter referred to as the “Company,” “we,” “us,” or “our”), a company incorporated under the laws of Samoa with registration number 94021 and registered address at Intershore Suite, Le Sanalele Complex, PO Box 608, Apia, Samoa, is committed to protecting user privacy.

This Privacy Policy (hereinafter referred to as the “Policy”) describes the procedures for the collection, use, storage, and protection of personal data of Users (hereinafter referred to as the “Data”) on the Allswaps NFT Platform.

1. Data We Collect

The Company follows the principle of data minimization and collects only the information necessary for the operation of the Platform:

Authentication Data: the cryptocurrency wallet address connected through WalletConnect.

Verification Data: e-mail address, Telegram username, and X/Twitter handle voluntarily provided by the User when completing verification tasks. Validation checks for disposable or spam addresses may be performed.

Activity Data: history of NFT-related operations (including minting and crafting), Energy balance, task completion statuses, and rewards received.

Technical Data: IP address, device and browser information, country-level geolocation, and session-related data.

Analytical Data: non-identifiable usage patterns collected through cookies.

Blockchain Data: transactions on the BNB Chain network are public; the Company may analyze wallet transaction history for AML/KYC compliance purposes.

The Company does not collect sensitive personal data (such as racial or ethnic origin, health information, political opinions, etc.), except where strictly required to comply with legal or regulatory obligations.

2. Legal Basis for Processing

Data processing is carried out on the following legal bases:

Consent: by connecting a wallet and providing verification data, the User consents to the processing of their Data.

Performance of a Contract: processing is necessary for the provision and operation of the Platform’s services.

Legitimate Interests: including fraud prevention, security assurance, and improvement of the Platform.

Legal Obligations: compliance with AML/KYC requirements and responding to lawful requests from competent authorities.

3. Purposes of Data Processing

Data is processed exclusively for the following purposes:

providing the services of the Platform (including authentication, minting, crafting, tasks, and rewards);
user verification and fraud prevention (including Sybil attacks, bots, and spam accounts);
compliance with AML/KYC requirements and sanctions compliance obligations;
analysis and improvement of the Platform’s functionality;
communications (including updates and notifications regarding changes to the Terms), with the option to opt out of marketing communications;
marketing activities, solely with the User’s explicit consent.

4. Data Sharing with Third Parties

Data may be disclosed to the following categories of recipients, subject to appropriate confidentiality safeguards:

Infrastructure Providers: hosting services, cloud providers, and analytics services operating under strict confidentiality agreements (NDAs).

Verification Providers: KYC/AML service providers (such as SumSub) where enhanced verification is required.

Government Authorities: where required by law (including court orders or regulatory requests) or where necessary to protect the rights of the Company.

Partners: for the purpose of distributing rewards (such as promotional codes), subject to the partners’ respective privacy policies.

The Company strictly prohibits the sale of personal data to third parties.

5. Data Security

The Company implements advanced technical and organizational security measures, including data encryption during transmission and storage (TLS/AES-256), role-based access control, regular security audits, and monitoring of suspicious activity.

Despite these measures, the Company cannot guarantee absolute security. The User acknowledges and accepts the residual risks associated with transmitting data over the internet. In the event of a data breach, the Company will notify affected Users and competent authorities within the timeframes required by applicable law.

6. User Rights

The User has the right to:

request access to their Data and obtain a copy of such Data;
request correction of inaccurate or incomplete Data;
request deletion of Data (subject to lawful grounds for retention);
request restriction of Data processing;
request data portability;
object to processing based on legitimate interests.

For residents of the EU/EEA (GDPR): the User additionally has the right to lodge a complaint with a competent data protection supervisory authority.

Requests may be submitted to privacy@allswaps.io and will be processed within 30 days. The Company may refuse a request where lawful grounds exist (including compliance obligations, legal disputes, or security considerations).

7. Data Retention

Data is retained only for as long as necessary to fulfill the purposes of processing:

authentication and activity data — for the duration of the User’s use of the Platform and for 12 months after the last recorded activity;
AML/KYC compliance data — for a minimum of 5 years from the date of the last transaction;
analytical data — in anonymized form without a defined retention period.

Upon expiration of the applicable retention periods, the Data will be irreversibly anonymized or securely deleted.

8. International Data Transfers

Data may be processed on servers located outside the User’s jurisdiction. The Company ensures an equivalent level of data protection through Standard Contractual Clauses or other recognized mechanisms for international data transfers.

9. Cookies and Tracking Technologies

The Platform uses only technically necessary (essential) cookies to ensure proper functionality. Advertising or analytics cookies are not used without the User’s prior consent. The User may manage cookie settings through their browser preferences.

10. Minors

The Platform is strictly prohibited for use by individuals under the age of 18. The Company does not knowingly collect personal data from minors. If such data is identified, it will be promptly deleted.

11. Changes to the Privacy Policy

The Company reserves the right to update this Policy. Material changes will be communicated to Users through the Platform. Continued use of the Platform after the publication of such updates constitutes acceptance of the revised Policy.

12. Contact Information

For privacy inquiries: support@allswaps.com

Smart Tech Support Limited
Intershore Suite, Le Sanalele Complex
PO Box 608
Apia, Samoa