Privacy Policy

1. Data Collection & Roles (GDPR & CCPA)

Under the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), AdSwap operates under two distinct roles:

• Data Controller (For Publishers): We collect minimal data necessary to maintain your account (Email address, developer name, and Firebase authentication identifiers) relying on the lawful basis of contractual necessity (Art. 6(1)(b) GDPR).
• Data Processor (For End-Users): When the AdSwap SDK runs inside your applications, we process end-user telemetry strictly to deliver contextual ads and prevent fraud.
• Public Data: Ad creatives, headlines, descriptions, and destination URLs submitted by you are explicitly intended for public global broadcast and do not constitute Private Identifiable Information (PII).

2. Anti-Fraud Telemetry & Edge Computing

AdSwap strictly adheres to the principle of Data Minimization. To mitigate click-fraud and bill impressions accurately, our Cloudflare Edge infrastructure processes end-user IP addresses temporarily for coarse geographic routing and rate-limiting. IP addresses are immediately anonymized or discarded from RAM. We do not deploy cookies for retargeting, nor do we conduct persistent cross-app behavioral profiling.

3. Payments & Third-Party Processors

For PRO memberships and wallet funding, all financial transactions, invoicing, and tax compliance are executed exclusively by our Merchant of Record, Lemon Squeezy. AdSwap does not collect, view, or store raw credit card details or banking data. Lemon Squeezy processes this data under their own Privacy Policy as an independent Data Controller for payments.

4. Transparency & Ad Disclosures (DSA & FTC)

In accordance with global advertising transparency standards, the US Federal Trade Commission (FTC) guidelines, and Article 26 of the EU Digital Services Act (DSA):

• All promotional placements rendered through the AdSwap SDK contain explicit advertisement identifiers (e.g., "Ad").
• Targeting criteria are strictly limited to contextual factors (application category, platform, regional geo-IP).
• AdSwap does not sell end-user personal data to third-party data brokers.

5. Data Retention & Your Rights (GDPR)

Under applicable data protection laws, you maintain the right to access, rectify, or erase your stored information ("Right to be Forgotten"). You may exercise your right to erasure at any time directly in your account dashboard by selecting "Delete Account".

This action triggers an automated pipeline that permanently and irreversibly purges your profile, associated ad creatives, media assets from object storage, and ledger records from our active databases.

6. Governing Law & Jurisdiction

This Privacy Policy and all matters arising out of or relating to it shall be governed by and construed in accordance with the laws of Italy. Any legal action or proceeding shall be brought exclusively in the competent Court of Turin (Tribunale di Torino, Italy).