Privacy Policy

1. Introduction

Welcome to Swetl ("we," "us," or "our"), a service provided by DIGIMERI OÜ, an Estonian company. This Privacy Policy explains how we collect, use, and share information about you when you use our website-based services at swetl.com (collectively referred to as the "Service").

Swetl provides personalized weight loss plans and calorie tracking features. We are committed to protecting your privacy and personal information.

By using Swetl, you agree to the collection and use of information in accordance with this policy. If you do not agree with any part of this policy, please do not use our Service.

2. Who We Are

Swetl is operated by:
DIGIMERI OÜ
16784825, Harju maakond, Tallinn, Kesklinna linnaosa, Pille tn 7/5-13, 10138, Estonia

For privacy-related inquiries, please contact us at: info'swetl.com

3. Information We Collect

3.1 Information you provide to us:

• Your account information, including your name, email address, and any other details you choose to provide
• Quiz answers and wellness assessment information
• Weight, height, and other health-related data you input
• Food and calorie tracking information
• Any other information you choose to provide through your use of the Service

3.2 Information we collect automatically:

• Usage data (e.g., frequency and duration of interactions with Swetl)
• Device information (e.g., device type, operating system, browser type)
• Approximate location (country or region) based on your IP address
• Data collected through tracking technologies like cookies and Facebook Meta Pixel

4. How We Collect Information

4.1 Direct Interactions:

When you interact with Swetl through the website, complete quizzes, or use our tracking features, we collect the information you provide during those interactions.

4.2 Automated Technologies:

We automatically collect certain information about your device and how you interact with the Service. This includes the use of cookies, server logs, and other tracking technologies.

4.3 Third-Party Sources:

We may receive information about you from third-party services that integrate with our Service, such as analytics providers.

5. How We Use Your Information

• Create and personalize your weight loss plans
• Provide and improve our Service
• Track your progress and provide insights
• Analyze usage patterns to enhance our capabilities
• Communicate with you about updates or changes to our Service
• Track user interactions for marketing purposes via Facebook Meta Pixel
• Detect and prevent fraud, abuse, and security incidents
• Comply with legal obligations and enforce our terms

6. Legal Basis for Processing (for EEA users)

For users in the European Economic Area (EEA), our legal basis for collecting and using your personal information will depend on the specific information concerned and the context in which we collect it. However, we will normally collect personal information from you only:

• Where we need it to perform a contract with you
• Where the processing is in our legitimate interests and not overridden by your rights
• Where we have your consent to do so

7. Data Retention and Security

7.1 Data Retention:

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

7.2 Security Measures:

We implement industry-standard security measures to protect your personal information. This includes:

• Encryption of data in transit and at rest
• Regular security audits and updates
• Access controls and authentication measures for our systems

However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

8. Sharing Your Information

We do not sell, rent, or share your personal information with third parties for their marketing purposes. We may share your information in the following circumstances:

• With service providers who help us operate and improve Swetl (e.g., cloud hosting providers, analytics services, and marketing partners)
• To comply with legal requirements or respond to lawful requests
• In connection with a merger, sale, or acquisition of all or a portion of our company

9. Tracking Technologies

We use tracking technologies like cookies and Facebook Meta Pixel to collect information about your use of the Service. This helps us understand how users interact with our websites and allows us to measure the effectiveness of our advertising efforts.

10. International Data Transfers

As we operate globally, your information may be transferred to, stored, and processed in countries other than your own. We will take appropriate measures to protect your personal information in accordance with this Privacy Policy and applicable data protection laws.

11. Your Rights and Choices

11.1 For all users:

• Access and Control: You can control the information you provide to Swetl
• Deletion: You may request to delete your account and associated data
• Opt-Out: You can choose to stop using Swetl at any time

11.2 For EEA users (and others where applicable):

• Right to access: Request a copy of your personal information
• Right to rectification: Ask us to correct or update your information
• Right to erasure: Request deletion of your information
• Right to restrict processing: Ask us to restrict processing
• Right to data portability: Request a copy in a machine-readable format
• Right to object: Object to our processing of your information
• Right to withdraw consent: Where we rely on consent, withdraw it at any time

12. Children's Privacy

Swetl is not intended for use by children under the age of 13. We don't knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new Privacy Policy on our website and updating the "Last Updated" date.

14. Third-Party Links and Services

Swetl may contain links to third-party websites or services that are not owned or controlled by us. We are not responsible for the privacy practices of these third parties. We encourage you to be aware when you leave our Service and to read the privacy policies of each website you visit.

15. Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at info@swetl.com.

17. Your Consent

By using Swetl, you acknowledge that you have read and understood this Privacy Policy and agree to its terms. You also consent to our collection, use, and sharing of your information as described in this policy.

18. Governing Law and Dispute Resolution

This Privacy Policy shall be governed by and construed in accordance with the laws of Estonia. Any dispute arising out of or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts in Estonia.

19. Supervisory Authority

If you are an EEA resident and believe we have not adequately addressed your data privacy concerns, you have the right to lodge a complaint with your local supervisory authority. In Estonia, this is the Estonian Data Protection Inspectorate (https://www.aki.ee/).