Last updated: August, 2025
1.1. Swipii is operated by Enigmatic Smile Limited (“Swipii”, “we”, “our”, or “us”) and is committed to protecting your privacy. This Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information”).
1.2. This Privacy Policy applies to your use of the loyalty program. The loyalty program gives you as a user the opportunity to obtain rewards (hereinafter referred to as “vUSD”) from the participating companies.
1.3. Please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in this Privacy Policy.
1.4. Enigmatic Smile Limited (ES) is the controller responsible for the personal information we hold about you (except as otherwise stated below). If you have any questions about this Privacy Policy or how we use your personal information, please contact us using the details set out in section 9 below.
2.1. We are committed to protecting your privacy. This Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information”).
2.2. The following sets out the categories of personal information we collect about you, how we use that information and the corresponding legal basis which we rely on to process the personal information:
When you create a user profile, you must enter your name, your e-mail address, your mobile phone number, a password and one or more payment cards.
Personal information about you is processed to be able to identify you as a user, including to be able to contact you. The processing of this information is necessary for Swipii for services to be delivered to you, including to be able to invoice companies for your earned vUSD. This processing is necessary for the agreement with you as a user to be fulfilled.
With your consent, your name, e-mail address and mobile phone number are also used for sending marketing material from Swipii.
We may collect other general personal information if you enter this in your user profile on the Swipii website or apps (“Platforms”). This could be for example, information about your date of birth, your age, number of people in your household, your gender, and your postcode. Entering such information is always optional for you.
However, we can make an estimate of your gender and your postcode based on your entered name and your geographical location, if you have given consent to the collection thereof.
This personal information is processed in order to carry out targeted marketing and offer you relevant opportunities to use Swipii.
We process information about your payment card number, expiry date and name of the cardholder. We only collect this information when you add your card details. In the event that you wish to make a payment for an additional service, you must also enter the card’s CVV/CVC. You may be asked to provide your CVV/CVC when registering your card. We do not store your CVV/CVC, but use this to authorize a specific payment or to authorize your card.
Your payment card information is only processed in an IT environment that is certified according to the PCI (Payment Card Industry) rules.
We need your card details in order to register which purchases you make where you are entitled to receive a vUSD reward. The processing is necessary to be able to fulfil the agreement with you.
We process information about the purchases you make with a payment card registered to Swipii. We process information about the time of purchase and the amount you purchased for. With your express consent, we also process information about where you made the payment. If you do not wish to notify us of your consent, we will not be able to provide service to you. We do not process information about what you have purchased, unless it is necessary for the purpose of calculating a reward.
Your payment information is processed so that we can calculate how much vUSD you are entitled to. This is necessary in order to fulfil the agreement with you.
With your consent, we also use information about your purchases for targeted marketing and to be able to offer you relevant opportunities to use Swipii.
Swipii processes your customer number in connection with payment of your vUSD rewards. Some payment methods require you to provide your customer number with the company to which the payment is to be made, e.g. if you want to offset a payment with your vUSD. Swipii only collects this information when if you provide it in order to collect rewards.
The purpose of the processing is that Swipii can allow you to use your vUSD in the manner that you have requested. For example, you may have asked that your vUSD be used for offsetting a bill or similar.
Where you opt to provide access in app, Swipii will process your contact list to check if anyone in your contact list already has an account with Swipii.
The purpose of processing this information is to make it easy for you to send rewards to other users within the app. In addition, it allows you to send an invite link to a person who is not already onboard.
With your consent, we process information about your geographical location.
The purpose of the processing is that Swipii can target its marketing and show you companies (shops, restaurants, webshops, etc.) that offer vUSD near you. We may also use your geographic location to make an estimate of your current residence post code.
Swipii may carry out profiling activities to better understand your preferences and provide you with personalised offers and marketing communications. This helps ensure that you receive content that is relevant to your interests and needs. Profiling does not restrict your access to any offers, products, or services, but rather enables us to tailor our marketing in a more meaningful way. Swipii only sends direct marketing via email if you have given your explicit consent.
The purpose of this processing is to deliver targeted marketing and personalised offers based on your user activity and preferences. This processing is based on your consent, which you may withdraw at any time. Profiling is carried out in a manner that respects your privacy and supports a better user experience.
With your consent we may use your personal information to train and enhance our artificial intelligence (AI) models in order to improve the overall performance and quality of our services. Any data used for this purpose will be anonymized or pseudonymized to ensure that your personal privacy is safeguarded and the data cannot be traced back to you.
The purpose of this processing is to support the development and improvement of our AI-driven features and services, enabling us to offer more accurate, efficient, and user-relevant experiences. The processing is based on our legitimate interest in enhancing our technology while maintaining strict data protection standards.
3.1. Swipii will not share your personal information with third parties without your consent, unless we have a valid legal basis to do so. Where necessary and in accordance with how we use your data, we may share your personal information with the following categories of recipients:
When you shop with a store, Swipii may share your age, gender, postal code, the amount spent, the vUSD paid to you, and the time of the transaction.
If you choose to “follow” a store on the Platforms, Swipii may also share your first name, age, gender, and postal code, along with the amount spent, the vUSD paid to you, and the time of the transaction. Additionally, your news feed may be updated with targeted marketing from that store.
Swipii may also pass on your personal information to comply with the law, in connection with a legal process and to comply with requests from public authorities.
3.2. We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.
3.3. As a user, you consent to your payment card being registered for rewards and to your card number being passed on to payment providers connected to Swipii. You also consent to these companies processing information about where, when and for what amount you have spent using your card in order to calculate your vUSD. Information about what you have purchased will not be processed.
3.4. We use the information we receive about your vUSD and collect from you to be able to create targeted marketing for you. In this connection, we pass on pseudonymised information to third parties for the purpose of optimizing our marketing efforts.
3.5. Swipii has concluded data processing agreements with its data processors. The agreements determine the obligations that the data processor must comply with when it processes your personal information on our behalf. The data processor can thus only legally process information about you to fulfil the stated purposes.
4.1. Security and Confidentiality. We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on secure servers. We take all reasonable steps and follow generally accepted industry standards to ensure that the personal information we hold is protected from misuse, interference, loss, unauthorized access, modification or disclosure by the use of various methods including access limitation, and industry-standard Secure Socket Layer (SSL) encryption technology.
Swipii treats your personal information confidentially. Selected employees at Enigmatic Smile Limited, Swipii and business partners are authorized to access data where necessary to solve usability or technical problems. All of Enigmatic Smile Limited’s, Swipii’s employees and business partners are subject to strict confidentiality requirements when processing personal information.
4.2. International transfers of your personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. Transfer of personal information only takes place when a necessary basis for transfer has been secured in accordance with local personal data regulations and where you have provided explicit consent. If you wish to enquire further about these safeguards used, please contact us using the details set out in section 9 below.
4.3. Retention of your information. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements. Swipii stores your personal information until you unsubscribe from the Swipii, after which your personal information is either deleted or pseudonymised. If you revoke a consent, the personal information previously processed under the consent will be deleted or anonymised, unless we have another legal basis for continued processing.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.
5.1. In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
5.2. If you wish to exercise one of these rights, please contact us using the details set out in section 9 below.
5.3. You can revoke one or more of your consents at any time by contacting Swipii, by deleting your profile or by changing your settings on the Platforms. If you revoke your consent, please note that in some cases you may not be able to use Swipii.
6.1. The service may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
7.1. The service is not directed at persons under 16 and we do not knowingly collect personal information from children. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.
8.1. We may update this Privacy Policy from time to time and so you should review this page periodically. When we change this Privacy Policy in a material way, we will update the “last modified” date at the end of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.
9.1. You can contact us with any queries in relation to data protection or this Privacy Policy by emailing us at [email protected].