Privacy Policy

1. Introduction

Swagrush (Pty) Ltd ("Swagrush", "we", "us", or "our") is committed to protecting your personal information in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information.

2. Information We Collect

We collect the following categories of personal information:

2.1 Information You Provide

• Registration details: Name, email address, phone number
• Profile information: Address, ID number (for KYC verification)
• Payment information: Processed through our secure payment provider (Ozow)
• Communication: Messages sent to our support team

2.2 Information Collected Automatically

• Device information: Browser type, operating system
• Usage data: Pages visited, features used, time spent
• Log data: IP address, access times, referring URLs

3. Purpose of Processing

We process your personal information for the following purposes:

• To provide and maintain our services
• To process purchases and deliver digital assets
• To manage promotional entries and prize draws
• To verify winner eligibility (KYC requirements)
• To communicate about your account and promotions
• To comply with legal and regulatory obligations
• To prevent fraud and ensure platform security
• To improve our services and user experience

4. Legal Basis for Processing

We process your personal information based on the following legal grounds under POPIA:

• Consent: Where you have provided explicit consent
• Contract: Necessary for performance of our services
• Legal obligation: Required by law (e.g., FICA, tax regulations)
• Legitimate interest: For fraud prevention and platform security

5. Data Sharing and Disclosure

We may share your information with:

• Payment processors: Ozow for transaction processing
• Service providers: Cloud hosting, email services
• Regulatory bodies: When required by law
• Prize fulfilment: Partners involved in prize delivery

We do not sell your personal information to third parties.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Secure authentication mechanisms
• Regular security assessments
• Access controls and audit logging
• Staff training on data protection

7. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required by law. Specifically:

• Account data: Duration of account plus 7 years
• Transaction records: 7 years (legal requirement)
• Competition entry records: 5 years
• Marketing preferences: Until consent is withdrawn

8. Your Rights Under POPIA

You have the following rights regarding your personal information:

• Access: Request confirmation and access to your data
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your data (subject to legal retention requirements)
• Objection: Object to processing of your information
• Withdrawal: Withdraw consent at any time
• Complaint: Lodge a complaint with the Information Regulator

To exercise these rights, contact our Information Officer at laurels@swagrush.app

9. Cookies and Tracking

We use essential cookies to ensure proper functioning of our platform. We may also use analytics cookies to understand how users interact with our services. You can manage cookie preferences through your browser settings.

10. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware of such collection, we will take steps to delete the information.

11. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated via email or platform notification. The "Last updated" date indicates when the policy was last revised.

12. Contact Us

For privacy-related inquiries or to exercise your rights: