Privacy Policy
Effective date: November 7, 2026 · Last updated: November 7, 2026
This Privacy Policy explains how SwiftCart Media Limited ("SwiftCart Media", "we", "us" or "our") collects, uses, shares, stores and deletes personal data when you:
- visit our website at swiftcartmedia.com (the "Website");
- use any mobile or web application published by SwiftCart Media Limited on the Apple App Store, Google Play or the web (each an "App"); or
- contact us or work with us as a client.
Together these are the "Services". This policy also serves as our Personal Information Collection Statement under the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") and as our privacy notice under the EU and UK General Data Protection Regulation ("GDPR").
In short: we collect only the data needed to run the Services, we never sell your personal data, payments are handled by Apple or Google (we never see your card details), and you can access, correct or delete your data at any time by emailing privacy@swiftcartmedia.com.
1. Who is responsible for your data
The data controller (data user under the PDPO) responsible for your personal data is:
SwiftCart Media Limited
Unit B, 3/F., Kai Wan House, 146 Tung Choi Street, Mongkok, Kowloon, Hong Kong
Email: privacy@swiftcartmedia.com
Phone: +43 677 63882574
Requests and questions about personal data are handled by our Privacy Officer at the address and email above. SwiftCart Media Limited is the developer and seller named on the App Store and Google Play listings of every App this policy covers.
When we build software for a client, we process data on that client's behalf and under the client's instructions. In that case the client's privacy policy applies, not this one.
2. Data we collect
Each App collects only the data its features need, so not every App collects every type of data listed below. The "App Privacy" section on the App Store and the "Data safety" section on Google Play show exactly what each App collects, and they match this policy.
| Category | Examples | Source |
|---|---|---|
| Contact details | Name, email address, phone number | You, when you email us, request support or create an account |
| Account data | Email, display name, encrypted password, account ID; profile data shared by Sign in with Apple or Google Sign-In | You, or the sign-in provider you choose |
| User content | Text, photos, files or other content you create or upload in an App | You |
| Purchase data | Products bought, subscription status, transaction ID, renewal dates (no card details) | Apple or Google |
| Device and usage data | Device model, operating system, app version, language, time zone, features used, session times | Collected automatically by the App |
| Diagnostics | Crash logs, error reports, performance data | Collected automatically by the App |
| Identifiers | App-specific install ID; device advertising ID (IDFA/GAID) only if you allow it | Collected automatically by the App |
| Approximate location | Country or city, derived from IP address | Collected automatically |
| Device permissions | Camera, photos, microphone, precise location, notifications | Only when you grant permission for a specific feature |
| Client information | Business contact details, project materials, invoices | Clients and prospective clients |
We do not intentionally collect sensitive data such as health, biometric, financial account, racial or religious information. If a future App needs it for a feature, that App will ask for your explicit consent first and this policy will be updated.
3. Why we use your data
- To provide the Services: creating and managing accounts, running App features, storing your content and syncing it across devices.
- To process purchases: unlocking paid features, verifying subscriptions and restoring purchases.
- To provide support: answering your questions, fixing problems and handling refund or deletion requests.
- To keep the Services working: diagnosing crashes, fixing bugs and improving performance.
- To improve the Services: understanding, mostly through aggregated statistics, which features are used.
- To show ads in free Apps: where an App contains ads (see section 8).
- To communicate with you: sending service messages such as receipts, security alerts and important changes. We send marketing messages only if you opt in, and you can opt out at any time.
- For safety and legal reasons: preventing fraud and abuse, enforcing our Terms, and meeting legal, tax and accounting obligations.
- For client projects: communicating with clients, delivering projects and invoicing.
We use your data only for these purposes, or for directly related ones. We will ask for your consent before using it for any new, unrelated purpose. We do not sell your personal data. We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.
4. Legal bases (EEA and UK users)
- Contract: to provide the Services you request, such as your account, purchases and support.
- Legitimate interests: to keep the Services secure, fix problems, understand usage in aggregate and respond to enquiries. We balance these interests against your rights, and you can object at any time.
- Consent: for personalised advertising, tracking, optional device permissions and marketing emails. You can withdraw consent at any time, and withdrawal doesn't affect processing that took place before it.
- Legal obligation: to keep tax and accounting records and to respond to lawful requests.
5. Is providing data required?
Giving us personal data is voluntary. Some data is needed for certain features: for example, you need an email address to create an account, and we need your contact details to answer a support request. If you don't provide it, we can't offer that feature, but you can usually still use the rest of the App. Device permissions are always optional and can be changed in your device settings.
6. Who we share data with
We share personal data only with the following types of recipients:
- Service providers (data processors) that host data, provide cloud infrastructure, analytics, crash reporting, email delivery, customer support tools or subscription management for us. They may use the data only to provide services to us, under written contracts that require them to protect it to a standard at least equal to this policy.
- Platform providers such as Apple and Google, which distribute our Apps and process payments under their own privacy policies.
- Advertising partners, only in Apps that show ads and only as described in section 8.
- Professional advisers such as accountants, auditors and lawyers, under confidentiality obligations.
- Authorities, when the law or a valid legal process requires it, or to protect the rights, safety or property of our users, the public or us.
- A buyer or successor, if our business is reorganised, merged or sold. Your data would remain protected by this policy.
We do not share personal data with anyone else without your consent.
7. Third-party services in our Apps
Depending on the App, we may use the following kinds of third-party services. Each App's store listing shows which ones it uses.
| Purpose | Typical providers | Data involved |
|---|---|---|
| Cloud hosting and databases | Google Firebase / Google Cloud, Amazon Web Services, Cloudflare | Account data, user content |
| Analytics and crash reporting | Google Analytics for Firebase, Firebase Crashlytics | Usage data, diagnostics, identifiers |
| Subscription management | RevenueCat | Purchase data, app-specific user ID |
| Advertising (free Apps only) | Google AdMob | Identifiers, approximate location, usage data |
| Sign-in | Sign in with Apple, Google Sign-In | Name and email you choose to share |
These providers have their own privacy policies. We choose providers that commit to protecting personal data to a standard at least as high as ours.
8. Advertising and tracking
Some free Apps may show ads. Ad partners may collect device identifiers, approximate location and app usage to show and measure ads.
- iPhone and iPad: we ask permission through Apple's App Tracking Transparency prompt before tracking you across other companies' apps or websites. If you say no, we don't track you, and any ads you see are not personalised.
- Android: you can reset your Advertising ID or turn off personalised ads in your device's Google settings.
- EEA, UK and Switzerland: we ask for your consent before showing personalised ads, using a consent tool certified under the IAB Transparency & Consent Framework.
If an App offers a paid upgrade that removes ads, the App description says so.
9. Purchases and subscriptions
In-app purchases and subscriptions are processed by Apple or Google. We never receive or store your full card or bank details. We receive confirmation of what you bought and your subscription status so we can unlock features and help you if something goes wrong.
10. AI-powered features
Some Apps may offer features powered by third-party artificial intelligence services, such as generating text or images. Where an App offers such a feature, it tells you before any of your content is sent to an AI provider and asks for your permission. We send only the content needed for the feature, and we use providers that do not use your content to train their models.
11. Website, cookies and Do Not Track
Our Website is a simple information site. It does not use advertising cookies, tracking cookies or analytics cookies, and it has no forms that collect personal data. Our hosting provider, Cloudflare, may process technical data such as IP addresses and may set strictly necessary cookies to keep the Website secure and fast.
Do Not Track: because the Website doesn't track visitors, it treats every visit as if a Do Not Track or Global Privacy Control signal had been sent. Our Apps follow the tracking choices you make in your device settings, as described in section 8.
12. How long we keep data
We keep personal data only as long as we need it for the purposes in this policy, then delete or anonymise it.
| Data | Retention period |
|---|---|
| Account data and user content | While your account is active. Deleted within 30 days after you delete your account. |
| Backups | Overwritten on a rolling basis within 35 days |
| Support emails | Up to 24 months after the conversation ends |
| Crash reports and diagnostics | Up to 90 days |
| Analytics data | Up to 14 months; anonymised aggregate statistics may be kept longer |
| Purchase, invoice and tax records | 7 years, as required by Hong Kong tax and accounting law |
| Fraud and abuse prevention records | Up to 12 months |
13. Deleting your account and data
If an App has accounts, you can delete your account from inside the App at Settings → Account → Delete Account. You can also delete it without the App by following our Account & Data Deletion page. When you delete your account, we delete your account data and user content within 30 days, except for the records described in section 12 that the law requires us to keep.
Deleting an App or your account does not cancel a subscription. Subscriptions are billed by Apple or Google and must be cancelled in your App Store or Google Play settings.
14. How we protect data
- All data sent between the Apps or Website and our servers is encrypted in transit (HTTPS/TLS).
- Data is stored with reputable cloud providers that encrypt it at rest.
- Access to personal data is limited to the people who need it for their work, and is protected by strong passwords and two-factor authentication.
- Passwords are never stored in plain text.
- We keep our software and dependencies up to date and review security regularly.
- If a data breach is likely to put you at risk, we will tell you and the relevant authorities as the law requires.
No system is completely secure, but we take reasonable and appropriate steps to protect your data.
15. International transfers
We are based in Hong Kong, and our service providers may process data in other countries, including the United States and member states of the European Union. When we transfer personal data out of the EEA, the UK or Hong Kong, we use appropriate safeguards, such as the European Commission's Standard Contractual Clauses or equivalent contractual protections, so your data stays protected to the standard described here.
16. Your rights
Depending on where you live, you may have the right to:
- Access the personal data we hold about you and get a copy of it;
- Correct personal data that is inaccurate or incomplete;
- Delete your personal data;
- Restrict or object to certain processing, including processing based on legitimate interests and direct marketing;
- Data portability: receive your data in a structured, machine-readable format;
- Withdraw consent at any time where we rely on it;
- Complain to a data protection authority, such as the Office of the Privacy Commissioner for Personal Data, Hong Kong, or the supervisory authority in your country of residence.
How to make a request: email privacy@swiftcartmedia.com or write to our Privacy Officer at the address in section 1. We may ask you to confirm your identity first. We respond within 30 days, and in any event within the 40 days allowed by the PDPO. We don't charge for requests, except that the PDPO allows us to charge a fee not exceeding our direct costs for repeated or unusually large access requests; we'll tell you the amount in advance. We will never treat you differently for exercising your rights.
17. California and other U.S. states
This section applies to residents of California and other U.S. states with consumer privacy laws.
- Categories collected in the last 12 months: identifiers, customer records (contact details), commercial information (purchase history), internet or other electronic network activity (usage and diagnostic data), approximate geolocation, and user content. Sources, purposes and recipients are described in sections 2, 3 and 6.
- Sale and sharing: we do not sell personal information for money. In Apps that show personalised ads, giving advertising partners identifiers may count as "sharing" for cross-context behavioural advertising under California law. You can opt out by declining tracking on iOS, turning off personalised ads on Android, or emailing us with the subject "Do Not Sell or Share".
- Sensitive personal information: we do not use or disclose it for purposes that require a right to limit.
- Your rights: to know, access, correct and delete personal information, and to opt out of sale or sharing. You may use an authorised agent with written permission. We will not discriminate against you for exercising these rights.
- Reviewing and changing your information: you can review and change most account information in the App, or email us.
18. Children
Our Services are not directed to children under 13, or under 16 in the EEA and UK, and we do not knowingly collect personal data from them. If you believe a child has given us personal data, contact us and we will delete it promptly. If we ever publish an App designed for children, it will comply with the U.S. Children's Online Privacy Protection Act (COPPA), Apple's Kids Category rules and Google Play's Families Policy, and it will not contain third-party analytics or advertising that those rules prohibit.
19. Changes to this policy
We may update this policy from time to time. We will post the new version on this page and change the "Last updated" date. If the changes are significant, we will also notify you in the App or by email before they take effect. If a change requires your consent, we will ask for it.
20. Contact us
If you have questions about this policy or your personal data, contact our Privacy Officer:
SwiftCart Media Limited — Attn: Privacy Officer
Unit B, 3/F., Kai Wan House, 146 Tung Choi Street, Mongkok, Kowloon, Hong Kong
Email: privacy@swiftcartmedia.com
Phone: +43 677 63882574