Cookie Policy

Effective July 31, 2025

1. Introduction

This Cookie Policy explains how Swapped ApS and its affiliated entities ("Swapped," "we," "us," or "our") use cookies and similar tracking technologies on our websites, mobile applications, and digital platforms (collectively, the "Services").

This Policy should be read together with our Privacy Policy. which provides comprehensive information about how we collect, use, and protect your personal data.

By continuing to use our Services, you acknowledge that you have read and understood this Cookie Policy. You can manage your cookie preferences at any time using the cookie settings available on our website.

2. What Are Cookies?

Cookies are small text files that are placed on your device (computer, smartphone, tablet, or other electronic device) when you visit a website. They are widely used to make websites work more efficiently and to provide information to website owners.

Cookies contain information that is transferred to your device's hard drive or memory. They allow a website to recognize your device and store some information about your preferences or past actions.

2.1 Similar Technologies

In addition to cookies, we may use other similar technologies, including:

• Web beacons (pixel tags): Small graphic images embedded in web pages or emails that allow us to determine whether you have performed specific actions

• Local storage: Technologies that allow websites to store data locally within your browser

• Session replay tools: Technologies that record user interactions with our website for analysis and improvement purposes

• Fingerprinting: Techniques that collect information about your device and browser configuration to create a unique identifier

3. Types of Cookies We Use

3.1 Essential Cookies (Strictly Necessary)

These cookies are essential for the operation of our Services and cannot be disabled. They are usually set in response to actions you take, such as logging into your account, setting privacy preferences, or filling in forms.

Purpose: Enable core functionality, security, and navigation Duration: Session cookies (deleted when you close your browser) or up to 1 year Legal Basis: Legitimate interest (necessary for service provision)

Examples include:

• Authentication cookies to keep you logged in

• Security cookies to prevent fraud

• Load balancing cookies to ensure optimal performance

• Cookie consent preferences

3.2 Analytics and Performance Cookies

These cookies help us understand how visitors interact with our Services by collecting and reporting information anonymously. This helps us improve the functionality and user experience of our platform.

3.2.1 Google Analytics

Provider: Google LLC / Google Ireland Limited

Purpose: Website traffic analysis, user behavior tracking, performance measurement

Duration: Up to 2 years

Data Collected: IP address (anonymized), device information, pages visited, time spent, referral sources, user interactions

Legal Basis: Consent (GDPR) / Legitimate interest where permitted

Cookies Used:

• _ga (2 years): Distinguishes unique users

• _ga_* (2 years): Contains campaign related information

• _gid (24 hours): Distinguishes users

• _gat (1 minute): Throttles request rate

Data Sharing: Google may process this data in the United States and other countries. Google is certified under the EU-US Data Privacy Framework.

Opt-out Options:

• Use our cookie preferences center

• Install the Google Analytics Opt-out Browser Add-on

• Enable "Do Not Track" in your browser settings

3.2.2 Ahrefs Analytics

Provider: Ahrefs Pte Ltd

Purpose: Website performance monitoring, SEO analysis, traffic insights

Duration: Up to 1 year

Data Collected: Page views, referral sources, search queries, user navigation patterns, device and browser information

Legal Basis: Consent (GDPR) / Legitimate interest for website optimization

Cookies Used:

• ahrefs-analytics (1 year): Tracks user sessions and page views

• ah_session (Session): Maintains session state

Data Processing: Ahrefs processes data in accordance with GDPR and maintains appropriate data protection safeguards.

3.3 Functional/Preference Cookies

These cookies allow our Services to remember choices you make (such as language preferences, currency settings, or form data) and provide enhanced, more personalized features.

Purpose: Remember user preferences and settings, enhance user experience Duration: Up to 1 year Legal Basis: Consent (GDPR) / Legitimate interest for user experience improvement

Examples include:

• Language and region preferences

• Currency display settings

• Theme preferences (light/dark mode)

• Recently viewed items or pages

• Form auto-fill data (non-sensitive)

3.4 Marketing and Advertising Cookies

Currently, Swapped does not use third-party marketing or advertising cookies. If we introduce such cookies in the future, we will update this Policy and seek your consent where required by law.

4. Cookie Duration and Types

4.1 Session Cookies

These cookies are temporary and are deleted when you close your browser. They are essential for basic website functionality during your browsing session.

4.2 Persistent Cookies

These cookies remain on your device for a specified period (from hours to years) and are reactivated when you revisit our website. They help us recognize you as a returning visitor.

4.3 First-Party Cookies

Set directly by Swapped when you visit our Services. We have full control over these cookies and the data they collect.

4.4 Third-Party Cookies

Set by external service providers (such as Google Analytics or Ahrefs) when you visit our Services. These are governed by the respective third party's privacy policy.

5. Legal Basis for Cookie Processing

5.1 European Union (GDPR)

Under the General Data Protection Regulation (GDPR), we process cookies based on the following legal grounds:

• Consent: For non-essential cookies (analytics, preferences, marketing), we obtain your explicit consent before setting these cookies

• Legitimate Interest: For essential cookies necessary to provide our Services and ensure security

• Contractual Necessity: For cookies required to fulfill our contractual obligations to provide the Services

5.2 United Kingdom

Under UK data protection law (UK GDPR and PECR), our approach mirrors the EU framework:

• Explicit consent for non-essential cookies

• Legitimate interest for essential functionality and security cookies

• Clear information and easy withdrawal of consent

5.3 United States

For users in the United States, including California residents subject to the CCPA/CPRA:

• We provide clear disclosure of our cookie practices

• You have the right to opt-out of the sale or sharing of personal information (we do not currently sell or share personal information through cookies)

• You may request deletion of personal information collected through cookies, subject to legal exceptions

5.4 Other Jurisdictions

For users in other countries, we apply privacy-protective practices consistent with local laws and international standards, including providing clear information about cookie use and respecting user preferences where technically feasible.

6. Your Cookie Choices and Rights

You have several options for managing cookies:

6.1 Cookie Preference Center

Use our cookie settings tool (accessible via the cookie banner or the "Cookie Settings" button on our website) to:

• Accept or reject different categories of cookies

• Change your preferences at any time

• View detailed information about each cookie category

6.2 Browser Settings

Most web browsers allow you to:

• Block all cookies

• Block third-party cookies only

• Delete existing cookies

• Set preferences for specific websites

• Receive notifications when cookies are set

Browser-Specific Instructions:

• Chrome: Settings > Privacy and Security > Cookies and other site data

• Firefox: Settings > Privacy & Security > Cookies and Site Data

• Safari: Preferences > Privacy > Manage Website Data

• Edge: Settings > Site permissions > Cookies and site data

6.3 Third-Party Opt-Outs

• Google Analytics: Google Analytics Opt-out

• Ahrefs: Contact their support or use browser settings to block their cookies

6.4 Mobile Device Settings

On mobile devices, you can usually find cookie settings within your browser's privacy or security section. Some mobile operating systems also provide app-level tracking controls.

7. International Data Transfers

7.1 Google Analytics

Google may transfer and process your data in the United States and other countries outside the European Economic Area (EEA). Google LLC is certified under the EU-US Data Privacy Framework and implements Standard Contractual Clauses (SCCs) where applicable.

7.2 Ahrefs Analytics

Ahrefs processes data in accordance with GDPR requirements and implements appropriate safeguards for international transfers, including Standard Contractual Clauses where necessary.

7.3 Safeguards

For all international transfers, we ensure that:

• Adequate safeguards are in place (such as SCCs or adequacy decisions)

• Data is processed only for the purposes specified in this Policy

• Recipients implement appropriate technical and organizational security measures

8. Data Retention

8.1 Cookie Data Retention Periods

• Essential cookies: Retained for the duration of your session or up to 1 year as necessary for functionality

• Google Analytics: Data is retained for 26 months by default, with IP addresses anonymized

• Ahrefs Analytics: Data retained for up to 1 year

• Preference cookies: Retained for up to 1 year to remember your settings

8.2 Data Deletion

When cookies expire or are deleted:

• Session data is immediately removed

• Persistent cookies are automatically deleted after their expiration date

• You can manually delete cookies through your browser settings at any time

9. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children through cookies or any other means. If we become aware that we have collected information from a child under 18, we will take steps to delete such information promptly.

10. Security

We implement appropriate technical and organizational measures to protect information collected through cookies, including:

• Encryption of sensitive data

• Secure transmission protocols (HTTPS)

• Access controls and authentication

• Regular security assessments and updates

11. Your Rights Under Data Protection Laws

Depending on your jurisdiction, you may have the following rights regarding personal data collected through cookies:

11.1 EU/UK Residents (GDPR/UK GDPR)

• Access: Request access to personal data processed through cookies

• Rectification: Request correction of inaccurate data

• Erasure: Request deletion of personal data (subject to legal exceptions)

• Portability: Request data in a machine-readable format

• Objection: Object to processing based on legitimate interests

• Restriction: Request limitation of processing

• Withdraw Consent: Withdraw consent for cookie processing at any time

11.2 US Residents

• Access and Deletion: Request access to and deletion of personal information

• Opt-out: Opt-out of sale or sharing of personal information (where applicable)

• Non-discrimination: Protection against discrimination for exercising privacy rights

11.3 Exercising Your Rights

To exercise your rights, contact us at:

• Email: support@swapped.com

• Data Protection Officer: GDPR@swapped.com

We will respond to valid requests within the timeframes required by applicable law (typically 30 days for GDPR requests).

12. Updates to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will:

• Post the updated Policy on our website

• Update the "Effective Date" at the top of this Policy

• Notify you through our Services or by email where required by law

• Request renewed consent where necessary

We encourage you to review this Policy periodically to stay informed about our cookie practices.

13. Complaints and Supervisory Authorities

If you have concerns about our cookie practices, you may:

1. Contact us directly using the details provided in Section 14

2. File a complaint with a supervisory authority:

13.1 EU/EEA Residents

Lead Supervisory Authority (Denmark): The Danish Data Protection Agency (Datatilsynet)

• Address: Carl Jacobsens Vej 35, 2500 Valby, Denmark

• Phone: +45 33 19 32 00

• Email: dt@datatilsynet.dk

• Website: https://www.datatilsynet.dk/english

13.2 UK Residents

Information Commissioner's Office (ICO)

• Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

• Phone: 0303 123 1113

• Website: https://ico.org.uk

13.3 Other Jurisdictions

Contact your local data protection authority or privacy regulator.

14. Contact Information

For questions about this Cookie Policy or to exercise your rights, contact us at:

Email: support@swapped.com

Data Protection Officer: GDPR@swapped.com

Postal Address: Swapped ApS Rosbjergvej 22A 8220 Brabrand, Denmark

15. Glossary

Cookie: A small text file stored on your device by a web browser while browsing a website.

Data Controller: The entity that determines the purposes and means of processing personal data.

Data Processor: An entity that processes personal data on behalf of a data controller.

Personal Data/Personal Information: Any information relating to an identified or identifiable natural person.

Session Cookie: A cookie that is deleted when you close your browser.

Persistent Cookie: A cookie that remains on your device for a specified period.

Third-Party Cookie: A cookie set by a domain other than the one you are visiting.