SwapU Privacy Policy

Version: 2.0
Last Updated: June 18, 2026
Effective Date: June 18, 2026

1. INTRODUCTION

SwapU ("we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our vehicle swapping platform.

This Policy Applies To:

The SwapU website (swapu.com.au)
Mobile applications (when available)
All services provided by SwapU

Australian Privacy Law Compliance:

Privacy Act 1988 (Cth)
Australian Privacy Principles (APPs)
Spam Act 2003
Do Not Call Register Act 2006

Contact: For privacy questions, email privacy@swapu.com.au

2. INFORMATION WE COLLECT

2.1 Information You Provide

Account Information:

Email address (required)
Phone number (optional, for SMS notifications)
Display name
Profile photo (optional)
Location (suburb or city)
Date of birth (to verify 18+ age requirement)

Vehicle Information:

Year, make, model
Registration details
VIN (Vehicle Identification Number)
Mileage (odometer reading)
Condition description
Photos of vehicle
Service records (optional)
Valuation information

Communication Data:

Messages with other users
Conversations with Nicholas AI
Support inquiries
Feedback and reviews

Financial Information:

Coordination fee payment records (the fee is processed by Stripe - see Section 2.5)
Coordination fee transaction history

Identity Documents:

SwapU does not currently collect government identity documents (such as a driver's licence or proof of address) and does not run third-party identity verification at this stage. If we introduce identity verification in future, this Policy will be updated first and you will be told what is collected and by whom.

2.2 Information Collected Automatically

Usage Data:

Pages viewed
Search queries
Listings viewed
Time spent on platform
Features used
Button clicks and interactions

Device Information:

IP address
Browser type and version
Operating system
Device type (mobile, tablet, desktop)
Screen resolution
Referral source

Location Data:

Approximate location (city/region) from IP address
Precise location (if you grant permission for meeting location suggestions)

2.3 Cookies and Tracking Technologies

We use cookies and similar technologies:

Essential Cookies: Required for platform functionality (login, session, preferences)
Analytics Cookies: Help us understand usage patterns (Google Analytics 4)

We do not currently run third-party advertising or ad-targeting cookies.

Cookie Control: You can disable cookies in your browser settings, but this may limit platform functionality.

2.4 Information from Third Parties

PPSR Reports:

If a PPSR report is ordered through the platform, we receive the vehicle encumbrance data returned by the register

SwapU accounts are created with email and password only — there is no Google, Facebook, or other social sign-in, so we do not receive profile information from social networks. We also do not currently use a third-party identity-verification service.

2.5 Payment Information

Stripe Processing: Payment card details are NOT stored by SwapU. All payment information is processed by Stripe (our payment processor) and subject to Stripe's Privacy Policy.

We receive from Stripe:

Last 4 digits of card
Transaction success/failure status
Payment amount and date

3. HOW WE USE YOUR INFORMATION

3.1 Primary Uses

Platform Functionality:

Create and manage your account
Display your vehicle listings
Match you with potential swap partners
Facilitate communication between users
Process the coordination fee
Provide customer support

AI Coordination (Nicholas AI):

Analyze your swap preferences
Generate personalized recommendations
Coordinate swap timelines
Draft communication messages
Identify potential issues or concerns

Safety and Verification:

Verify your identity
Prevent fraud and abuse
Detect suspicious activity
Protect user safety

Legal Compliance:

Comply with legal obligations
Respond to legal requests
Enforce our Terms of Service
Resolve disputes

3.2 Communications

We may contact you for:

Transactional messages: Swap updates, payment confirmations, security alerts
Notifications: New match found, message received, meeting scheduled
Marketing: Platform updates, new features, tips (you can opt out)
Surveys: Feedback requests to improve the platform

Opting Out:

Transactional messages: Cannot opt out (essential for service)
Marketing emails: Click "Unsubscribe" link in any email
SMS notifications: Reply STOP to any SMS
Push notifications: Disable in device settings

3.3 Analytics and Improvement

Platform Improvement:

Analyze usage patterns to improve features
Test new features with user groups
Measure platform performance
Identify and fix bugs

Matching Algorithm:

Improve matching accuracy using historical swap data
Train AI models on successful swaps
Optimize recommendations

3.4 Aggregate Data

We create anonymized, aggregate statistics for:

Public reporting (e.g., "1,000 swaps completed")
Research and analysis
Marketing materials
Industry reports

Aggregate data cannot identify you personally.

4. HOW WE SHARE YOUR INFORMATION

4.1 With Other Users

Public Profile Information:

Display name
Profile photo
Location (suburb/city only)
User rating/reviews

When You Express Interest:

Your vehicle details shared with potential swap partner
Your contact information (after both parties agree to connect)

When Swap Agreed:

Full contact details (email, phone)
Vehicle documents (for inspection)
Meeting location details

4.2 Service Providers

We share data with third-party providers who help us operate the platform:

Firebase / Google Cloud (Hosting, Database & Authentication):

Account data, listings, messages, authentication
Data stored in the Sydney, Australia region
Subject to the Google Cloud Privacy Policy

Stripe (Payment Processing):

Coordination fee payment information
Subject to the Stripe Privacy Policy

Resend (Email Delivery):

Email address and email content
For transactional and service emails

Twilio (SMS — optional):

Phone number and message content, only if you opt in to SMS notifications
Subject to the Twilio Privacy Policy

Anthropic (AI Services for Nicholas AI):

Conversation data used to generate Nicholas AI responses
Anthropic servers may be located outside Australia (see Section 8)
Subject to Anthropic's Privacy Policy

Google Analytics 4 (Usage Analytics):

Pseudonymous usage and device data
Subject to the Google Privacy Policy; you can opt out (see Section 9)

4.3 Legal Requirements

We may disclose information:

To comply with law: Court orders, subpoenas, legal processes
To protect rights: Enforce Terms of Service, investigate violations
To prevent harm: Fraud, security threats, illegal activity
In emergencies: Imminent danger to person or property

4.4 Business Transfers

If SwapU is acquired or merges with another company, your information may be transferred to the new owner. We'll notify you before your information is subject to a different privacy policy.

4.5 With Your Consent

We may share information for other purposes with your explicit consent.

5. DATA SECURITY

5.1 Security Measures

We implement technical and organizational measures to protect your data:

Technical Safeguards:

Encryption in transit (TLS/SSL)
Encryption at rest (AES-256)
Secure authentication (Firebase Auth)
Regular security audits
Intrusion detection systems

Organizational Safeguards:

Access controls (need-to-know basis)
Employee training on data protection
Confidentiality agreements
Incident response procedures

5.2 Your Responsibility

You are responsible for:

Keeping your password confidential
Using a strong, unique password
Logging out on shared devices
Reporting suspicious activity immediately

5.3 No Absolute Security

Important: No security system is 100% secure. While we take reasonable measures, we cannot guarantee absolute security of your data.

6. YOUR RIGHTS

6.1 Access Your Data

You have the right to request a copy of your personal information. Email privacy@swapu.com.au with your request.

We'll provide:

Account information
Listing history
Message history
Transaction records

Response Time: Within 30 days of verified request.

6.2 Correct Your Data

You can update most information directly in your account settings. For other corrections, contact privacy@swapu.com.au.

6.3 Delete Your Data

Account Deletion:

Email support@swapu.com.au requesting account deletion
We'll delete your account within 30 days
Some data retained for legal compliance (see Section 6.7)

Partial Deletion:

Delete specific listings
Remove profile photo
Clear message history

6.4 Restrict Processing

You can request we limit how we use your data in certain situations:

You contest the accuracy of data
Processing is unlawful but you don't want deletion
We no longer need the data but you need it for legal claims

6.5 Data Portability

You can request your data in a portable format (JSON, CSV) to transfer to another service.

6.6 Object to Processing

You can object to:

Marketing communications (opt out anytime)
Automated decision-making (request human review)
Use of data for specific purposes

6.7 Data Retention

Active Accounts:

Data retained while your account is active

Deleted Accounts:

Most data deleted within 30 days
Backup copies deleted within 90 days
Retained for legal compliance (12 months):
- Transaction records (tax, financial reporting)
- Legal agreements (dispute resolution)
- Fraud prevention data

Legal Holds:

Data subject to legal proceedings retained until resolved

7. CHILDREN'S PRIVACY

SwapU is NOT intended for users under 18 years of age.

We do NOT knowingly:

Collect data from children under 18
Allow children to create accounts
Market to children

If we discover a child's account, we'll delete it immediately.

Parents: If you believe your child has created an account, contact privacy@swapu.com.au immediately.

8. INTERNATIONAL DATA TRANSFERS

Primary Data Location: Australia (Firebase Sydney region)

AI Processing: Anthropic servers may be located outside Australia. Data is:

Encrypted in transit
Processed per Anthropic's privacy policy
Subject to appropriate safeguards

User Location: Platform intended for Australian users. If you access from outside Australia, your data may be subject to Australian law.

9. COOKIES AND TRACKING

9.1 Cookie Types

Essential Cookies (Cannot Disable):

firebase:auth - Authentication session
firebase:anonymous - Anonymous user tracking
session_id - Platform session

Analytics Cookies (Can Disable):

_ga - Google Analytics 4 client identifier
_ga_* - Google Analytics 4 session/property identifier

Preference Cookies (Can Disable):

location - Saved location preference

9.2 Managing Cookies

Browser Settings:

Chrome: Settings → Privacy → Cookies
Firefox: Preferences → Privacy → Cookies
Safari: Preferences → Privacy → Cookies

Opt-Out Tools:

Google Analytics Opt-Out: tools.google.com/dlpage/gaoptout

9.3 Do Not Track

We currently do not respond to browser Do Not Track signals, but we respect your cookie preferences.

10. THIRD-PARTY LINKS

The Platform may contain links to third-party websites:

PPSR (ppsr.gov.au)
Insurance providers
Mechanic directories
Legal resources

We are NOT responsible for:

Privacy practices of third-party sites
Content on third-party sites
Use of your data by third parties

Review their privacy policies before providing personal information.

11. CHANGES TO THIS PRIVACY POLICY

11.1 Right to Modify

We may update this Privacy Policy to reflect:

Changes in our practices
Changes in law
New features or services
User feedback

11.2 Notification

For material changes:

Email notification to your registered email
Prominent notice on Platform
30 days' notice before changes take effect

For minor changes:

Updated "Last Updated" date
Continued use constitutes acceptance

11.3 Version History

Previous versions available upon request.

12. COMPLAINTS AND DISPUTES

12.1 Internal Complaints

If you have a privacy concern:

Email privacy@swapu.com.au with details
We'll acknowledge within 5 business days
We'll investigate and respond within 30 days
We'll work with you to resolve the issue

12.2 External Complaints

If you're not satisfied with our response, you can lodge a complaint with:

Office of the Australian Information Commissioner (OAIC)
Website: oaic.gov.au
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Mail: GPO Box 5218, Sydney NSW 2001

12.3 Governing Law

This Privacy Policy is governed by Australian law (Queensland jurisdiction).

13. CONTACT INFORMATION

Privacy Officer: Nicholas (Founder)
Email: privacy@swapu.com.au
Support: support@swapu.com.au
Address: Brisbane, Queensland, Australia

For privacy requests:

Access your data
Correct your data
Delete your account
Opt out of marketing
Lodge a complaint

14. CONSENT

By using SwapU, you consent to:

Collection of your personal information as described
Use of your information for purposes stated
Disclosure to third parties as outlined
Storage in Australia and potential processing overseas
Use of cookies and tracking technologies

You can withdraw consent by deleting your account, but this will prevent you from using the Platform.

15. ACKNOWLEDGMENT

By clicking "I Accept" or using the Platform, you acknowledge that:

✓ You have read and understood this Privacy Policy
✓ You consent to collection and use of your data as described
✓ You understand your rights regarding your personal information
✓ You are at least 18 years of age
✓ You understand data is stored in Australia
✓ You agree to receive necessary transactional communications

END OF PRIVACY POLICY

This Privacy Policy is a draft prepared for implementation and will be reviewed by a qualified lawyer before final public launch.