1. Who Is Responsible
The controller responsible for processing your personal data under the EU General Data Protection Regulation (GDPR) is:
SwiftAlgo UG (haftungsbeschränkt)
Rupperather Ring 12
53902 Bad Münstereifel
Germany
Managing directors: Luc Wiengarten, Niklas Keller
Email: mail@swiftalgo.net
In this policy, “SwiftAlgo”, “we” and “us” mean SwiftAlgo UG (haftungsbeschränkt), and “Swift Algo” means our indicator for TradingView. For questions about privacy or to exercise your rights, email mail@swiftalgo.net.
2. Legal Bases
We only process personal data when the law allows it. Depending on the purpose, the legal basis is:
- your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time with effect for the future;
- the performance of a contract with you, or steps you ask for before entering into one (Art. 6(1)(b) GDPR);
- a legal obligation we are subject to, for example tax and commercial record-keeping (Art. 6(1)(c) GDPR);
- our legitimate interests (Art. 6(1)(f) GDPR), where they are not overridden by your interests, rights and freedoms.
Storing information on your device or reading it from your device, for example through cookies or pixels, requires your consent unless it is strictly necessary to provide the service you asked for (§ 25 of the German Telecommunications Digital Services Data Protection Act, TDDDG).
3. Visiting Our Website
Hosting and server logs
Our website is hosted by an external hosting provider. When you visit it, your browser automatically sends information that is processed in server log files: your IP address, the date and time of access, the page requested, the referring page, your browser and operating system, and the amount of data transferred.
We use this data to deliver the website, keep it secure and fix errors. The legal basis is our legitimate interest in a secure, working website (Art. 6(1)(f) GDPR). Log data is kept only as long as needed for these purposes and then deleted, unless a specific security incident requires us to keep it longer.
Google Fonts
Our pages load fonts from Google Fonts, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. When a page loads, your browser connects to Google’s servers, which receive your IP address. Google may also process this data in the USA.
We use Google Fonts to display our website consistently. The legal basis is our legitimate interest in a consistent presentation (Art. 6(1)(f) GDPR). More information: policies.google.com/privacy.
Embedded video (Vimeo)
The walkthrough video on our homepage and the setup video on the page you see after buying are embedded from Vimeo, a service of Vimeo.com, Inc., USA. When the page loads, your browser connects to Vimeo’s servers, which receive your IP address and technical information about your device. We embed the video with Vimeo’s “do not track” setting, which tells the player not to track your session. When you play the video, Vimeo processes information about the playback.
We use Vimeo to show how our product works. The legal basis is our legitimate interest in presenting our product (Art. 6(1)(f) GDPR). More information: vimeo.com/privacy.
4. Cookies and Consent
Our website does not need cookies to work. We only load the Whop Pixel, the Google tag and any other advertising or conversion tracking tool described in Advertising and Conversion Tracking, after you click “Accept” in our cookie banner (Art. 6(1)(a) GDPR, § 25(1) TDDDG). If you click “Decline”, these tools are not loaded.
You can change your choice at any time via “Cookie settings” at the bottom of our homepage. If you withdraw your consent, we delete these tools’ cookies and stored data from your browser and stop loading them. Withdrawing your consent does not affect the lawfulness of processing carried out before the withdrawal.
We store your choice in your browser’s local storage for up to twelve months, so that we do not have to ask again on every visit. This is necessary to respect your choice (Art. 6(1)(c) GDPR, § 25(2) TDDDG).
You can also block or delete cookies in your browser settings. Our website still works if you do.
5. Advertising and Conversion Tracking
We advertise Swift Algo on Facebook and Instagram through Whop Ads, the advertising service of our checkout partner Whop, and on Google. With your consent, we use the tools below to find out which ads and visits lead to purchases and to improve how our ads are shown. They process data such as your IP address, device, browser and time zone information, the pages you visit, the ad or link you came from (including click IDs such as fbclid and gclid and campaign parameters in the page address), and your visits and purchases on our Whop checkout.
The legal basis for loading the Whop Pixel and the Google tag on our website is your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG). Without your consent, they are not loaded. Tracking on Whop’s own checkout pages is carried out by Whop under its own privacy policy. The providers keep the data according to their own retention periods.
Whop Pixel
Provider: Whop Inc., USA.
The Whop Pixel is a script on our website. It sets cookies (_wuid and _wuid_link, stored for up to two years) and uses your browser’s storage to recognise your browser, reads the ad and campaign parameters in the page address, and adds an identifier to links to our Whop checkout. This lets Whop connect a purchase to the visit and the ad that led to it. Whop also records checkout views, purchases, subscriptions and trial starts on its checkout. More information: whop.com/privacy.
Meta (Facebook and Instagram) via Whop Ads
Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. Meta may also transfer data to Meta Platforms, Inc. in the USA.
Our ads on Facebook and Instagram run through Whop Ads. Whop sends conversion events, such as purchases, to Meta through Meta’s Conversions API, including contact details such as your email address in hashed (encrypted) form, so that Meta can match purchases to the ads it showed and improve how they are delivered. We do not place a Meta Pixel on our website. More information: facebook.com/privacy/policy; ad settings in your Meta account.
Google Ads (Google tag)
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google may also transfer data to Google LLC in the USA.
We use the Google tag to measure which of our Google ads lead to purchases. When you arrive on our website from a Google ad, the Google tag stores the ad click identifier (gclid) in cookies on our domain (_gcl_au and _gcl_aw, stored for up to 90 days). If you then buy Swift Algo, the page you see after your purchase reports the purchase to Google with the payment reference Whop gives us, so that Google can count it for the ad you clicked and does not count it twice. We do not send Google your name, email address or payment details, and we do not use the Google tag for remarketing or personalised advertising. More information: policies.google.com/privacy; ad settings in your Google account.
Other advertising platforms
If we also advertise on X, we may use the X Pixel (X Corp., USA, or its Irish affiliate for users in the EU, EEA and UK) for conversion tracking. We will add it to our cookie banner before we use it, and it will only load with your consent. More information: x.com/en/privacy.
6. Buying Swift Algo
Swift Algo is sold through Whop (Whop Inc., USA). When you buy, Whop processes your account, contact, billing and payment data under its own responsibility and privacy policy (whop.com/privacy). Payments are processed by the payment providers Whop uses, for example card payment processors and PayPal. We do not receive or store your full payment card details.
From Whop we receive the information we need to provide your membership: your name, email address, the plan you bought, your payment and subscription status, your billing country where available, and the TradingView username you submit. We use it to give you access, provide support, handle billing questions, prevent misuse such as shared access, and meet our accounting and tax obligations. The legal bases are the performance of our contract with you (Art. 6(1)(b) GDPR), our legal obligations (Art. 6(1)(c) GDPR) and, for preventing misuse, our legitimate interest in protecting our product (Art. 6(1)(f) GDPR).
Providing this data is necessary to buy and use Swift Algo. Without it, we cannot provide the service.
7. Access on TradingView
Swift Algo runs on TradingView (TradingView, Inc., USA). To give you access, we add the TradingView username you submitted to the access list of our invite-only script on TradingView, and we remove it when your membership ends. TradingView processes your account data under its own privacy policy (tradingview.com/privacy-policy). The legal basis is the performance of our contract with you (Art. 6(1)(b) GDPR).
8. Emails
Purchase emails. We send you the emails needed for your membership, such as order confirmations, access instructions, billing and renewal notices and important updates about the service. The legal basis is the performance of our contract with you (Art. 6(1)(b) GDPR). These emails are sent through Whop or our email service provider.
Marketing emails. If you are a customer, we may send you emails about updates, offers and similar products from SwiftAlgo to the email address you used for your purchase. The legal basis is our legitimate interest in direct marketing (Art. 6(1)(f) GDPR in conjunction with § 7(3) of the German Act Against Unfair Competition, UWG). You can object at any time, free of charge, using the unsubscribe link in every such email or by emailing mail@swiftalgo.net, and we will stop sending them. Where we ask for your consent to other marketing, the legal basis is your consent (Art. 6(1)(a) GDPR).
9. Contacting Us and Support
If you email us at support@swiftalgo.net or mail@swiftalgo.net, we process your email address, your message and any information you share in order to answer you. If your request relates to a purchase or your membership, the legal basis is the performance of our contract with you or steps before one (Art. 6(1)(b) GDPR); otherwise it is our legitimate interest in answering enquiries (Art. 6(1)(f) GDPR). Our email accounts are hosted by an email service provider.
10. Discord Community
Our community runs on Discord (Discord Inc., USA). Discord processes your account data and activity under its own privacy policy (discord.com/privacy).
When you join our server, we and our moderators can see your Discord username, your profile and the messages you post there, and other members can read your messages. We process this to run and moderate the community, based on our legitimate interest in operating it (Art. 6(1)(f) GDPR), and to give paying members access to member-only channels, based on the performance of our contract (Art. 6(1)(b) GDPR).
11. Reviews on Our Website
Our website shows selected customer reviews from our public Whop store, with the reviewer’s name or username and how long after purchase the review was written. We do this based on our legitimate interest in showing genuine customer feedback (Art. 6(1)(f) GDPR). If you wrote one of these reviews and do not want it shown on our website, email mail@swiftalgo.net and we will remove it.
12. Recipients and International Transfers
We only share personal data as described in this policy: with our hosting and email service providers, Whop and its payment providers, TradingView, Discord, Vimeo, Google (Google Fonts and Google Ads), Meta (through Whop Ads) and, if we use them, other advertising platforms, and with authorities where we are legally required to, for example tax authorities. Service providers that process data on our behalf do so under data processing agreements (Art. 28 GDPR).
Some of these providers are based in the USA or process data there. For companies certified under the EU-US Data Privacy Framework, transfers are based on the European Commission’s adequacy decision (Art. 45 GDPR). Where a provider is not certified, transfers are based on the Standard Contractual Clauses adopted by the European Commission (Art. 46(2)(c) GDPR).
13. How Long We Keep Data
We delete personal data when it is no longer needed for the purpose it was collected for, unless the law requires us to keep it. In particular:
- membership and customer data: for the duration of your membership, and afterwards for as long as claims can be made, usually three years from the end of the year in which your membership ended (§§ 195, 199 BGB);
- invoices and accounting records: for as long as German commercial and tax law requires, up to ten years (§ 147 AO, § 257 HGB);
- emails and support requests: until your request is resolved, and longer only where they matter for a contract or a legal obligation;
- marketing emails: until you unsubscribe, after which we keep a record of your objection so that we do not email you again;
- server logs: only as long as needed for security and operation;
- advertising and conversion tracking: the Whop Pixel’s cookies are stored for up to two years and the Google tag’s cookies for up to 90 days, and data held by Whop and the advertising platforms is kept according to their own retention periods;
- your cookie choice: up to twelve months.
14. Your Rights
Under the GDPR, you have the right to:
- access the personal data we hold about you (Art. 15 GDPR);
- have inaccurate data corrected (Art. 16 GDPR);
- have your data deleted (Art. 17 GDPR);
- have processing restricted (Art. 18 GDPR);
- receive your data in a structured, commonly used and machine-readable format (Art. 20 GDPR);
- withdraw any consent you have given, at any time and with effect for the future (Art. 7(3) GDPR).
To exercise your rights, email mail@swiftalgo.net. We may ask you to confirm your identity before we respond.
15. Right to Object
You have the right to object at any time, on grounds relating to your particular situation, to processing of your personal data that is based on our legitimate interests (Art. 6(1)(f) GDPR). We will then stop processing it, unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is needed to establish, exercise or defend legal claims (Art. 21(1) GDPR).
You can object at any time, without giving reasons, to the use of your personal data for direct marketing. We will then no longer use your data for this purpose (Art. 21(2) and (3) GDPR).
16. Complaints to a Supervisory Authority
You have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the EU member state where you live, where you work or where the alleged infringement took place. The authority responsible for us is:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Kavalleriestraße 2–4
40213 Düsseldorf
Germany
17. Visitors from the United States
This policy describes the categories of personal information we collect, where it comes from, why we use it and who we share it with. We do not sell personal information for money. We use the Whop Pixel and the Google tag, and share conversion data with Meta through Whop Ads, which some US state laws treat as “sharing” personal information for targeted advertising.
The Whop Pixel and the Google tag only load if you accept them in our cookie banner, and you can change your choice at any time via “Cookie settings” at the bottom of our homepage. You can also use your browser settings, the ad settings of each platform and industry opt-out tools such as optout.aboutads.info. Our website does not respond to “Do Not Track” browser signals.
18. Children
Swift Algo is only for people aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a minor has given us personal data, email mail@swiftalgo.net and we will delete it.
19. Security and Automated Decisions
Our website is only served over an encrypted connection (HTTPS). We use appropriate technical and organisational measures to protect your data, but no method of transmission or storage is completely secure.
We do not make decisions based solely on automated processing, including profiling, that have legal effects on you or similarly significantly affect you (Art. 22 GDPR).
20. Changes to This Privacy Policy
We update this policy when our website, our services or the law change. The current version is always available on this page, and the date at the top shows when it was last updated. If a change significantly affects how we use data you have already given us, we will inform customers by email.