Swappie Privacy Notice

Welcome to our Privacy Notice. Here we tell you what kind of personal data we collect about you, how we use it and what are your rights as a data subject. This Privacy Notice applies to you if you are:

  • Our customer or a potential customer
  • Visitor to our website
  • A representative or contact person of our corporate customer or business partner

Swappie Oy (“we”, “us”, or “Swappie”) is the data controller of the data described in this Privacy Notice. Please note that if Swappie acts as a data processor for its corporate customers or partners, you should refer to privacy notices of those parties for information on the collection and processing of your personal data. 

Please also note that Swappie’s website may contain links to other websites. Our Privacy Notice applies only to our website, so if you click on a link to another website, you should familiarise yourself with their privacy notice.

To make finding the information you need a bit easier, we have divided the information provided under the following topics that we hope help you in navigating through this notice:

  • What data is collected and for what purposes?
  • Cookies
  • Marketing 
  • Data disclosures
  • How long do we store your data and how do we keep it secure?
  • What are your data protection rights?
  • Changes to our privacy policy
  • Contact information

What data is collected and for what purposes?

This section explains what personal data Swappie collects about you, for which purposes, how the data is collected, and the legal basis for it. Please note that more than one of the categories below may apply to you (e.g. you are our customer and you use our website, you should read all the relevant paragraphs).

If you are Swappie’s customer, we collect the following information about you: 

  • First and last name
  • Contact information
  • Your bank account details if you are selling your device to us
  • Other details of the transaction, e.g. product type
  • Your payment information
  • Communications you may have with us

This information is provided by you when you enter into the transaction with us, e.g. by filling out our online form, or when you otherwise communicate with us. We use the information for the purposes of processing your transaction, providing customer service for you, communication with you regarding your transaction and managing your account in relation to your customership. We may also use the data for the purposes of providing advertising to you, within the limits of legal requirements, and you may always choose to opt-out from the advertising communications whenever you like by unsubscribing. We may additionally carry out customer surveys, where we use the above mentioned data to contact you and may collect further information from you of your customer experience, preferences, and other feedback.

Please note that when you carry out a payment or payment subscription on our website, your transaction and payment details will be submitted to our payment service partner providing the payment function. Similarly, we will share the details of your order to our logistics partner for the purposes of making the delivery to you or alternatively organising the collection of the product from you. If you are choosing a deferred payment option and therefore applying for credit, our  payment service providers may carry out credit checking activities to ensure your creditworthiness. Please refer to the relevant partner’s privacy notice for further info on their data processing activities. 

The legal basis for collecting and processing the above data is fulfilling the contract between you and us, and, to the extent used for marketing or customer survey purposes, our legitimate interest to advertise our products and services to you and develop our business. If you subscribe to our newsletter in connection with making a transaction with us, the legal basis for processing your data in relation to this is your consent, and you may revoke it by unsubscribing to our newsletter. Please see more information on our marketing practices below under the section “Marketing”.

If we are subject to a legal obligation requiring us to do so, or if it is necessary for fraud prevention activities, carried out in our legitimate interest, we may also collect additional identifying information from you, such as your ID copy or ID number. In addition, we and our payment service partners may use fraud prevention technologies to ensure that we are entering into a legitimate transaction with you and to block possible attempts to make purchases e.g. with stolen identities or payment information. When we do this, it is based on our legitimate interest to avoid frauds and criminal behaviour in our business, and the data collected from you may be matched with public information or databases to deduct the fraud risk level in the specific case.

If you consent to our marketing or otherwise submit your details to us: If you consent to our marketing (e.g. subscribe to our newsletter), we collect your contact information and information about your consent status. Legal basis for collecting and processing this data is your consent, and it is used for the purposes of providing our marketing communications to you, and you may opt-out from this at any point by unsubscribing following the instructions in the marketing messages or by contacting us. From time to time we may also organise different kinds of campaigns or competitions, where you can provide us with your contact details and possible other information relating to the specific campaign in connection with your participation. Legal basis for collecting and processing this data is entering into and performing the contract concerning the campaign, and the data is used for the purposes of carrying out the campaign or competition activities and contacting you in relation to your participation in it. 

When you visit our website certain technical and other information is automatically sent by your device to us (i.e. IP address, browser and device details and the source of your visit). The information is used for the purposes of providing the website and the services included in it to you, the legal basis for it being our legitimate interest or entering into and performance of a contract between you and us, depending on the situation. We may also collect information about your website usage information by using cookies. For information on data collected via cookies and similar technologies, please see the section “Cookies” below.

If you are a representative or contact person of our corporate customer or business partner, or an individual entrepreneur collaborating with us, we collect the following information about you:

  • Name and contact details, and, if you are an individual entrepreneur, data that is necessary to identify you as our contractual counterparty
  • Position and other information about your connection to our customer/business partner
  • Possible details about our interactions and your preferences

This information is either provided directly by you when you communicate with us, or, if you are not in direct contact with us first, we receive the data from your organisation and its other representatives we are communicating with. We use this information for the purposes of managing our relationship and executing the contract with the corporate customer / our business partners and communicating in relation to this. The legal basis for data processing is our legitimate interest in relation to managing the contractual relationship and cooperation with the customer or business partner, and additionally, if you are an individual that is our contract counterparty, performance of the agreement between us. 

If we are obligated to report transactions related to our collaboration to tax authorities we may also need to collect your personal tax identification number and the basis for collection and purpose of processing this data is complying with a legal obligation we are subject to.


Cookies are pieces of data that websites store on your browser or device when you visit them. When cookies are activated they collect certain personal data about you via your device and browser. The cookies we use may collect the following information:

  • IP address
  • Browser type, version and session identifiers
  • Device type and operating system
  • URL trail on the website, time spent and actions on the website
  • Time of visit and city-level location

The extent of information listed above that is collected depends on the type of the cookies that are activated. You can choose not to allow the types of cookies that are not strictly necessary for operation of our website via our cookie banner prompted to you when landing on our website. You can also use your browser settings to delete cookies that have already been set at any time. 

We use cookies for the following purposes:

  • Ensuring our website functions (‘strictly necessary cookies’)
  • Providing enhanced functionality and personalisation on our website (‘functional cookies’)
  • To provide personalised advertising to you (‘advertising cookies’)
  • Measuring, analysing and improving our website’s performance (‘performance cookies’) 

Legal basis for collection of the personal data via the cookies is, for strictly necessary cookies, our legitimate interest, or entering into and performance of a contract between you and us, depending on the situation, and for the rest of the cookies, the consent you have given us (if you so choose) by clicking accept for the chosen cookies on our cookie banner.

For more detailed information of the cookies currently in use on our website, please refer to the cookies listing at the bottom of this page.


As stated above, we may use some of your personal data for the purposes of providing advertising to you. In this section we tell a bit more about our marketing activities and practices.

If you have given us your consent for marketing, e.g. by subscribing to our newsletter, or the law otherwise gives us the right to contact you based on our legitimate interest, we may send you communications and advertisements on our products and services, offers and campaigns, or other relevant news on activities of Swappie or its partners. We may send you these communications via email or SMS, depending on the contact details you have given us. As stated above, you have always the right to unsubscribe to these communications by following the unsubscribe instructions provided to you in each communication or marketing message. You may also contact us via the contact details listed below to unsubscribe. 

Data disclosures

We share personal data within the Swappie group of companies for the purposes set out above. In addition, in order to fulfil some of the purposes described in this notice, we may share some of your personal data with our service providers or commercial partners, such as parties that provide services for us or carry out actions on our behalf to provide the services to or enable the transaction with you, e.g. our logistics and payment services partners, our IT service providers, consultants, or our partners participating in your customer journey via our collaboration (e.g. our trade-in or drop-off partners). If you have consented to third-party cookies, or subscribed to our newsletters or marketing activities we may share your personal data with these third party cookies providers and our marketing partners that carry out the purpose of processing for us.

We may also disclose personal data to parties outside Swappie if:

  • It is required by law, for example in a case where we have to disclose personal data in order to respond to a request made by a public authority or law enforcement agency.
  • Disclosing your personal data is necessary to ensure safety and protect the rights of Swappie, our partners, our customers or you, or for the purposes of public interest in accordance with the law.
  • We become involved in a merger, acquisition or any form of sale of all or some of our assets, we may share and/or transfer your personal data in connection with the evaluation of and entry into such transactions.
  • In any other situation where we have obtained your consent for such transfer.

As some of our service providers and partners are located outside the European Economic Area, we may need to transfer personal data outside the European Economic Area in order to carry out our operations. Transfers of this kind are done according to the requirements of the applicable laws, and by following the applicable safeguards for the transfers, e.g. based on adequacy decisions on the level of data protection adopted by European Commission, or using standard contractual clauses approved by European Commission.

How long do we store your data and how do we keep it secure?

As a general rule, personal data is retained until it is no longer necessary for the purposes described above. The retention terms can be longer if we are under a legal obligation to retain, for example under accounting laws, certain kinds of data in accordance with the retention times set forth in the law. Additionally, if we need to keep any information longer for our legitimate interest of protecting our legal rights we will keep the necessary information for this purpose based on statutes of limitations or, if applicable, until the relevant claim(s) has/have been finally settled.

We apply both technical and organisational measures to keep your personal data secure. We have put in place physical, administrative, and technical security measures to ensure security of processing of your personal data and its confidentiality. Your data can only be accessed by persons for whom it is necessary in relation to their work.

What are your data protection rights?

In accordance with and within the limits of applicable legislation, you have the following rights:

Right to access your personal data – You have the right to know if we are processing your personal data, and an access to such personal data.

Right to correct your personal data – If you consider your personal data to be inaccurate or incomplete, you can request such personal data to be corrected.

Right to be forgotten – You have the right to request deletion of your personal data, to the extent permitted by law.

Right to restrict processing – In certain situations, you have the right to request restriction of the processing of your personal data.

Right to object processing – In certain situations, you have the right to object to the processing of your personal data.

Right to withdraw your consent – Where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.

Right to transfer your personal data – Where legally applicable, you have the right to have the personal data you have provided to us be returned to you in a commonly used, machine-readable format, or, where technically feasible, transferred to a third party.

If you would like to exercise any of these rights, please contact us via the contact information provided at the end of this Privacy Notice. Please note that some of these rights are not absolute and certain limitations may apply when exercising them.

Changes to Swappie’s Privacy Notice

We may update this Privacy Notice due to changes in our processing operations or in applicable legislation. When this happens we will make the updated Privacy Notice available here on our website. 

Contact information

If you have any questions about this Privacy Notice, the personal data we hold of you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Data controller contact information:

Name: Swappie Oy

Business ID: 2692328-4

Address: Itämerenkatu 3A, 00180 Helsinki, Finland

Telephone number: +358104063821

Email address: privacy (at) swappie.com

Website: www.swappie.com

Should you wish to lodge a complaint or if you feel that Swappie has not addressed your concern in a satisfactory manner, you may contact the competent local supervisory authority of the country of your location, or the supervisory authority of our location, the Finnish Data Protection Ombudsman.