Privacy Policy

UK GDPR & Data Protection Act 2018 Compliant

Version 1.0 | Effective: January 2026

📋1. Data Controller

The data controller responsible for processing your personal data under the UK GDPR and Data Protection Act 2018 is:

DDreamLab Ltd.

Managing Director: Denis Kros

Address: Zangwill 15, Netanya, Israel

Phone: +972-52-748-1659

UK Domain: swingroad.co.uk

Data Protection Enquiries: privacy@swingroad.co.uk

⚖️2. Data Protection Principles

We process personal data in accordance with the following principles (Article 5 UK GDPR):

✓Lawfulness, fairness and transparency
✓Purpose limitation - collected for specified, explicit and legitimate purposes
✓Data minimisation - adequate, relevant and limited to what is necessary
✓Accuracy - accurate and kept up to date
✓Storage limitation - kept no longer than necessary
✓Integrity and confidentiality - appropriate security measures

📜3. Legal Basis for Processing

We process personal data only on one of the following legal bases:

Article 6(1)(a) UK GDPR - Consent

You have given consent to the processing.

Article 6(1)(b) UK GDPR - Contract

Processing is necessary for the performance of a contract.

Article 6(1)(c) UK GDPR - Legal Obligation

Processing is necessary for compliance with a legal obligation.

Article 6(1)(f) UK GDPR - Legitimate Interests

Processing is necessary for our legitimate interests.

📊4. Categories of Personal Data

4.1 Account Data (upon registration)

•Name or pseudonym (username)
•Email address
•Date of birth / age
•Gender and gender identity
•Location (city/region)
•Profile photos (optional)
•Profile description and interests

Legal basis: Article 6(1)(b) UK GDPR (Contract)

4.2 Special Category Data (Article 9 UK GDPR)

Due to the nature of our platform, the following sensitive data may be processed:

•Data concerning sex life or sexual orientation
•Relationship status and type
•Intimate preferences

⚠️ This data is processed only with your explicit consent (Article 9(2)(a) UK GDPR). Providing this information is voluntary. You may withdraw your consent at any time with effect for the future.

4.3 Usage Data (automatically collected)

•IP address (anonymised after 7 days)
•Browser type and version
•Operating system
•Date and time of access
•Referrer URL
•Pages and features accessed

Legal basis: Article 6(1)(f) UK GDPR (Legitimate interest in security and optimisation)

4.4 Communication Data

•Messages sent through the platform
•Support enquiries
•Reports about other users

Legal basis: Article 6(1)(b) UK GDPR (Contract)

4.5 Payment Data

•Transaction data (amount, date, product)
•Payment method (no card details stored)

Legal basis: Article 6(1)(b) UK GDPR (Contract), Article 6(1)(c) UK GDPR (Legal obligation - tax records)

🤝5. Data Recipients

🔒 We do not sell your personal data to third parties.

Data may be shared with the following recipients:

5.1 Other Users

Profile information according to your privacy settings.

5.2 Data Processors

• Google Firebase/Cloud (USA): Hosting, database, authentication
• Payment processors: Payment processing
• Email service providers: Sending emails

All processors have signed data processing agreements in compliance with UK GDPR.

5.3 Authorities

When required by law (e.g., court orders, law enforcement).

🌍6. International Data Transfers

Some of our service providers are located outside the UK. Data transfers are protected by:

USA (Google Firebase)

• UK-US Data Bridge (adequacy regulations)
• International Data Transfer Agreement (IDTA)
• Additional technical and organisational measures

Israel (Company headquarters)

UK adequacy regulations - Israel provides an adequate level of data protection.

⏰7. Data Retention

We retain personal data only as long as necessary for the relevant purposes:

•Account data: While your account is active
•After account deletion: Deleted within 30 days (except legal retention requirements)
•Billing data: 6 years (UK tax requirements)
•Server logs: Maximum 90 days
•Backups: Maximum 30 days after deletion

⚖️8. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

📖 Right of Access (Article 15)

You can request information about your stored data, including a copy.

✏️ Right to Rectification (Article 16)

You can request correction of inaccurate or completion of incomplete data.

🗑️ Right to Erasure / "Right to be Forgotten" (Article 17)

You can request deletion of your data when there is no reason for continued storage.

⏸️ Right to Restriction (Article 18)

You can request restriction of processing in certain circumstances.

📦 Right to Data Portability (Article 20)

You can receive your data in a structured, commonly used format.

🚫 Right to Object (Article 21)

You can object to processing, particularly for direct marketing.

↩️ Right to Withdraw Consent (Article 7(3))

You can withdraw consent at any time with effect for the future.

📧 Exercising Your Rights

To exercise your rights, contact us at: privacy@swingroad.co.uk
We will respond to your request without undue delay and within one month (Article 12(3) UK GDPR).

🏛️9. Right to Complain

You have the right to lodge a complaint with a supervisory authority if you believe your data has been processed unlawfully (Article 77 UK GDPR).

UK Supervisory Authority:

Information Commissioner's Office (ICO)

Wycliffe House, Water Lane

Wilmslow, Cheshire SK9 5AF

Phone: 0303 123 1113

Website: ico.org.uk

🍪10. Cookies

We use cookies and similar technologies. For detailed information, please see our Cookie Policy.

You can manage your cookie preferences through our cookie consent banner or your browser settings.

🔐11. Data Security

We implement appropriate technical and organisational measures to protect your data:

✓SSL/TLS encryption for data in transit
✓Encryption of sensitive data at rest
✓Regular security audits and updates
✓Access controls and authentication
✓Staff training on data protection

📝12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by email or through a notice on our website. The date of the last update is shown at the top of this policy.

📄Related Documents

🏢

About Us

Company information and contact details

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📜

Terms and conditions for using our platform

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🍪

Cookie Policy

Information about cookies and tracking

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Last Updated: January 2026