Privacy Policy

1. Who We Are and Scope

Swivel operates the Swivel marketplace platform. This Privacy Policy explains how we collect, use, share, and protect information when you use our website and apps. By using the Platform, you agree to the practices described here.

For privacy questions or requests, contact us at privacy@swivelgh.app. For legal notices, use legal@swivelgh.app.

This policy applies to personal data collected through our websites, mobile apps, and related services (the "Platform"). It does not apply to third-party services you access through Swivel.

2. Information We Collect

We collect information you provide, information from transactions, and information collected automatically.

3. Legal Bases for Processing

We process personal data under the following legal bases, as applicable: contract performance (providing the service), legal obligations (tax, accounting, and fraud prevention), legitimate interests (security, analytics, and service improvement), and consent (marketing or optional cookies where required).

• Contract: Account creation, listing, checkout, escrow, refunds, and dispute resolution.
• Legal obligation: Compliance with financial regulations, tax requirements, and lawful requests.
• Legitimate interests: Security monitoring, fraud prevention, and service analytics.
• Consent: Optional marketing communications and non-essential cookies where required.

4. How We Use Your Information

• Provide, operate, and maintain the Platform.
• Verify seller eligibility and prevent fraud.
• Facilitate escrow payments, payouts, refunds, and dispute resolution.
• Communicate with you about your account, transactions, and support.
• Improve, test, and personalize the Platform.
• Comply with legal and regulatory obligations.

We may also use de-identified or aggregated data for analytics, reporting, and product improvements.

5. How We Share Your Information

We only share data as needed to provide the service or when required by law.

• With Other Users: Your profile name, listing details, and reviews are visible to other users.
• With Service Providers: Payment processors (e.g., Paystack), cloud hosting, analytics, customer support tools, and delivery partners.
• For Legal Reasons: When required by law, court order, or valid legal request.
• Business Transfers: If we undergo a merger, acquisition, or asset sale, user data may be transferred under confidentiality safeguards.

We do not sell personal data. We also limit access to personal data on a need-to-know basis and require service providers to protect data under contract.

6. Cookies and Tracking

We use cookies and similar technologies for essential functionality, security, analytics, and preferences. You can control cookies through your browser settings, and where required, we will request consent for non-essential cookies.

• Essential: Login, security, and session continuity.
• Analytics: Usage measurement and performance monitoring.
• Preferences: Remembering settings and language choices.

If you disable cookies, some features may not function properly. Do Not Track signals are not uniformly supported across browsers, but we honor cookie preferences where provided.

7. International Data Transfers

We may process and store information outside Ghana. When we transfer data internationally, we use appropriate safeguards such as contractual protections and vendor due diligence.

We will only transfer data to service providers that demonstrate appropriate security and privacy practices.

8. Data Retention

We retain personal data only for as long as necessary to provide the Platform, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary by data type and may be extended where required by law.

• Account data: Retained while your account is active and for a reasonable period after closure.
• Transaction records: Retained for audit, tax, and dispute resolution requirements.
• Support records: Retained to improve service quality and resolve issues.

9. Data Security

We use administrative, technical, and physical safeguards to protect your information. No security system is impenetrable, but we work to minimize risk and respond to incidents promptly.

Security measures include access controls, encryption in transit where supported, and monitoring for suspicious activity. Users are responsible for keeping their login credentials secure.

10. Your Rights

Under Ghana's Data Protection Act, 2012 (Act 843) and applicable international standards, you may have rights to access, correct, delete, restrict, or object to processing, and to withdraw consent where processing is based on consent. You may also request a copy of your data in a portable format. To exercise rights, contact privacy@swivelgh.app.

If you are located in the EEA, UK, or other regions with privacy laws, you may have additional rights such as data portability and the right to lodge a complaint with your local data protection authority.

11. Children’s Privacy

The Platform is not directed to children under 18. If we learn that we have collected personal data from a child without appropriate consent, we will delete it.

Parents or guardians who believe their child has provided us personal data should contact us at the email above.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will post updates on this page and update the effective date above.

If changes are material, we will provide additional notice through the Platform or by email where required.

Contact

If you have questions about this Privacy Policy, please contact privacy@swivelgh.app.

Last updated: May 25, 2026