Zwipe Privacy Policy

1. Scope

• The Website (hosted on Webflow), which provides information, Early Access forms, and support forms.
• The App (available on the Apple App Store and Google Play Store), which allows users to create accounts, list and browse vehicles, accessories, and related content.

2. Data We Collect

(a) Website forms

• Early Access Form: name, email, phone number, emirate/city, type of user (buyer/seller/dealer), feature interest, optional comments.
• Support Form: name, email, message content.

(b) Automatically collected Website data

• IP address, browser type/version, device type/OS, pages visited, and time spent.
• Stored temporarily in Webflow logs (~30 days) for security and operational purposes.
• Not linked to your identity unless you submit a form (and even then, only for operational/security purposes).

(c) App account data

• Username, email, phone number.
• Dealer verification: Emirates ID or trade licence copy (if required for compliance).
• Listings, chats, and reports submitted by you.
• Crash logs and device identifiers (via Firebase).

(d) Payment data

• Payments for boosts or subscriptions are processed only through Apple App Store or Google Play Store.
• Zwipe does not store or process your credit/debit card information directly.
• Subscription management is handled by RevenueCat, which acts as an intermediary between Zwipe and Apple/Google.

3. Purposes of Processing

• Provide launch announcements and updates.
• Send marketing communications related to Zwipe (opt-out available).
• Enable account creation, listings, chat, and boosts in the App.
• Improve features, user experience, and platform security.
• Handle inquiries and support requests.
• Perform analytics (aggregated, not user profiling).
• Comply with UAE laws, Free Zone/VAT rules, and lawful authority requests.

4. Lawful Basis for Processing

• Consent – when you submit data via forms or opt in to marketing.
• Contractual necessity – to provide the services you request via the App.
• Legitimate interests – improving services, ensuring security, preventing fraud.
• Legal obligation – complying with UAE Free Zone, VAT, AML, consumer protection, and data protection laws.

5. Data Retention

• Early Access form data – retained indefinitely unless you request deletion.
• Support form data – retained for 12 months unless needed longer for legal, fraud-prevention, or operational purposes.
• App account data – retained while your account is active and for up to six (6) years after closure to comply with UAE record-keeping laws and limitation periods.
• Dealer KYC data (if collected) – retained for the legally required minimum under UAE AML/CTF rules.

6. Data Storage & Security

• Website data – hosted on Webflow servers in the United States.
• App data – hosted on Firebase servers in Doha (Qatar, me-central1) and Mumbai (India, asia-south1).
• Technical safeguards include: SSL/TLS encryption, access controls, firewalls, SOC 2 & ISO 27001 certified providers.
• Contractual safeguards (DPAs with Firebase & Webflow) will also be implemented.

7. Cross-Border Transfers

8. Data Sharing

• Webflow (hosting/forms), Firebase (app hosting & crash reporting), Google Workspace (email), RevenueCat(subscription management).
• Apple App Store & Google Play Store (payment processing).
• Legal authorities when required.
• Internal authorized staff for moderation, support, and operations.

9. Cookies & Analytics

• Website: No marketing or profiling cookies. Only essential cookies (set by Webflow) for session/form handling.
• App: Firebase automatically collects app usage metrics and crash logs. No advertising or behavioral profiling is enabled.

10. Breach Notification

• Affected users without undue delay (via email or in-app).
• The UAE Data Office, TDRA, and—if applicable—relevant EU supervisory authorities.

11. Your Rights

• Access your data.
• Correct inaccuracies.
• Withdraw consent.
• Request deletion.
• Restrict or object to processing.
• File a complaint with the UAE Data Office (or with an EU supervisory authority if applicable).

12. Contact