Swivre Members ("we", "us") is committed to protecting your personal data. This Privacy Policy explains what data we collect, why, how long we keep it, and what your rights are. We process data in accordance with the General Data Protection Regulation (GDPR, EU 2016/679).

Who We Are (Data Controller)

Trade name Swivre 

Legal form VOF (General Partnership, Dutch law)

Country The Netherlands

Email info@swivre.com

KvK number xx

Website www.swivre.com

What Data We Collect, Why and How Long

We only collect personal data where necessary. The table below sets out exactly what we collect, the purpose, and the legal basis under the GDPR:

Data collected Purpose Legal basis Duration

Name, email, address Account creation and management Contract (Art. 6(1)(b) GDPR) + 1 year

Payment data via Mollie Process membership payments Contract (Art. 6(1)(b) GDPR) 7 years (tax obligation)

Portal usage and login logs Security, fraud prevention, improvement Legitimate interest (Art. 6(1)(f) GDPR) 1 year

Email for newsletters Membership updates and offers Consent (Art. 6(1)(a) GDPR) Until consent withdrawn

IP address, device, browser Security and analytics Legitimate interest (Art. 6(1)(f) GDPR) 12 months

Who We Share Data With

We do not sell personal data. We share data only with the following third parties, and only to the extent necessary:

• Mollie Payments B.V. — payment processing (data processing agreement in place)

• Email service provider — transactional and marketing emails (data processing agreement in place)

• Hosting and portal infrastructure provider — data stored within the EEA

• Analytics provider — aggregated and anonymised usage data only

We do not share personally identifiable data with Brand Partners. If we ever introduce a feature involving sharing personal data with a Brand Partner, we will request your explicit consent beforehand.

International Transfers

We store and process your data within the European Economic Area (EEA). If a service provider processes data outside the EEA, we ensure appropriate safeguards are in place (Standard Contractual Clauses or an adequacy decision) as required by Chapter V of the GDPR.

Your Rights Under the GDPR

As an EU resident, you have the following rights regarding your personal data:

• Right of access — request a copy of the data we hold about you

• Right to rectification — ask us to correct inaccurate or incomplete data

• Right to erasure — ask us to delete your data (“right to be forgotten”)

• Right to restriction — ask us to limit how we process your data

• Right to data portability — receive your data in a structured, machine-readable format

• Right to object — object to processing based on legitimate interests or for direct marketing

• Right to withdraw consent — where processing is based on consent, withdraw it at any time without affecting prior processing

To exercise any right, contact us at info@swivre.com. We will respond within 30 days. You also have the right to lodge a complaint with the Dutch supervisory authority: Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl), or the supervisory authority in your country of residence.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss or disclosure. These include encrypted connections (HTTPS), access controls, and regular security reviews. In the event of a data breach posing a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and inform affected members without undue delay.

Children

Swivre Members is not intended for persons under 18. We do not knowingly collect data from minors. If you believe we have inadvertently collected data about a minor, contact us and we will delete it promptly.

Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes by email and by updating the version date above. The current version is always available at www.swivre.com/privacy.

Contact

Questions about this Privacy Policy or your personal data? Contact us at: info@swivre.com