Last modified: October 18, 2023

Introduction:
Interop Software Labs Inc. (the “Company” or “We”) takes protecting your privacy very seriously. This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the Swing.xyz website located at https://www.swing.xyz, https://platform.swing.xyz/ or https://galaxy.exchange (the “Website”), and our practices for collecting, using, protecting, maintaining, and disclosing that information.

This Privacy Policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and the Company.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries). or
• Any third party (including our affiliates and subsidiaries), including through any application or content that may link to or be accessible from or on the Website. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

Please read this Privacy Policy carefully to understand how we interact with your personal information and what we do with it. By using the Website and providing us with your information, you agree to this Privacy Policy. This policy may change from time to time, and by continuing to use the Website, you agree to those changes. We encourage you to check this Privacy Policy periodically for updates.

The terms “us,” “we,” or “our” refer to the Company.

Children Under the Age of 18:

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to us, including on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any blockchain identity or records related to you. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at support@swing.xyz.

The Kinds of Personal Information We Collect:

Information You Provide to Us: The information we collect on or through our Website may include:

• Your public key address or other public identifier related to your blockchain account or activity.
• The email address that you provide us with.
• Your IP address.
• Information that you provide by filling in forms on our Website. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
• By which you may be personally identified, such as name and e-mail address (“personal information”)
• Records and copies of your correspondence (including email addresses) if you contact us.

Information Collect Automatically: When using our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Information about your internet connection.
• Information about the equipment, software, and configurations you use to access our website
• Usage details, including the total time you spend on our website, the time you spend on each page and in what order those pages were visited and the internal links clicked, the general geographic location from which you access our Website, which browser and operating system you are using to visit our Website, and the referring website.
• Performance details, including monitor page load times, CPU/memory usage, browser crashes and React component rendering.

The information we collect automatically is only statistical data and does not, itself, include personal information, though it may be correlated with other personal information to build a unique profile about you (for example, in relation to your publicly viewable blockchain activities; see Privacy & The Blockchain). Nonetheless, we do not perform such associations to build unique user profiles and only use this information to help us improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies [alone or in conjunction with web beacons or other tracking technologies] to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. [In addition to helping advertisers reach the right people for their products and services, behavioural advertising helps support our Website so that you can enjoy free content. You have the right to opt-out of third-party ad servers and cookies. We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information & Why We Collect It:

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Website.
• To help facilitate the ongoing development of our services.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please click the “unsubscribe” link or follow the unsubscribe instructions in such a communication. For more information, see Disclosure of Your Information.

Disclosure of Your Information:

We may disclose aggregated information, and information that does not directly identify any individual about our users without restriction. We may disclose personal information that you provide to us as described in this Privacy Policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our Website and services.
• To a buyer or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding.
• To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use, API Licensing Agreement if applicable, and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, credit risk reduction, or identifying malicious actors using our products, or related blockchain communities generally.

We do not sell your personal information to third-parties for monetary compensation.


Privacy & The Blockchain:
A key feature of many blockchain technologies, including any blockchain on which the Company’s services rely, is the transparency and public accessibility of on-chain transactions. This includes but is in no way limited to your public sending address (“public key”) and any other information that you choose to include. Additionally, information stored on-chain may be public, immutable, and not easily removed or deleted and, in many cases, cannot be deleted. Your public addresses may reveal information about you and this information can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement. If you are unfamiliar with blockchain technology and its transparent and public nature, we strongly encourage you to conduct your own research into blockchain before electing to use our services.

Your Choices:

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties' products or services, you can opt-out by clicking the “unsubscribe” link at the bottom of such an email that we send you.

Data Security:
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. This applies to any private keys you may use in relation to our Website or our services. We ask you not to share your password or private keys with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Special Disclosures for European Users:

Under the European General Data Protection Act, every user is entitled to the following:

• The right to access – You have the right to request for copies of your personal data from us. We may charge you a small fee for this service.
• The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
• The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
• The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
• The right to data portability – You have the right to request we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at support@swing.xyz.

Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

What if I have questions about this Privacy Policy?
If you have any questions about this Privacy Policy, please send us a detailed message to support@swing.xyz and we will try to resolve your concerns and provide further information.