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Privacy Policy

Last Updated: November 15, 2025

1. Introduction and Data Controller

This Privacy Policy (“Policy”) outlines the data processing practices for the services provided by Martim Miguel Pinheiro Benedito (acting as a Sole Proprietor, “we,” “us,” or “our”).

This Policy is divided into parts:

  • Part A applies to the swishforce.com website (“Website”).
  • Part B applies to the SWISH FORCE® Scoreboard mobile application (“Scoreboard App”).
  • Part C outlines processing for the forthcoming SWISH FORCE® Statistics application.
  • General Provisions (Sections 2, 6, 7, 8, 9) apply to all Services.

Data Controller:

  • Legal Entity: Martim Miguel Pinheiro Benedito
  • Brand: SWISH FORCE®
  • Address: Rua Manuel Ferreira 27, 2º Esq, 2795-229 Linda-a-Velha, Portugal
  • Contact Email: support@swishforce.com

2. General Principles & Your Rights (GDPR)

We process your data in compliance with the General Data Protection Regulation (GDPR). As a Data Subject, you have the right to:

  • Access: Request a copy of the data we hold about you.
  • Rectification: Request correction of inaccurate data.
  • Erasure (“Right to be Forgotten”): Request the deletion of your data.
  • Restriction: Request a halt on the processing of your data.
  • Portability: Request your data in a machine-readable format.
  • Object: Object to processing based on our legitimate interests.

To exercise these rights, please contact us at support@swishforce.com. You also have the right to lodge a complaint with the Portuguese Data Protection Commission (CNPD).

3. Part A: Data Processing – swishforce.com Website

This section applies only to data collected via the swishforce.com website.

Data Category: Contact Data (e.g., Email, Name via contact form)

  • Purpose of Processing: To respond to your inquiries submitted via our Website.
  • Legal Basis (GDPR): Art. 6(1)(f) – Legitimate Interest (Responding to user inquiries).

Data Category: Cookies & Analytics Data (IP Address, Browser type, Page views)

  • Purpose of Processing: To analyze website traffic, ensure security, and improve user experience. We use essential cookies for site function and analytics cookies (e.g., Google Analytics) to understand traffic patterns.
  • Legal Basis (GDPR): Art. 6(1)(a) – Consent (For non-essential/analytics cookies) or Art. 6(1)(f) – Legitimate Interest (For essential/security cookies).

4. Part B: Data Processing – SWISH FORCE® Scoreboard App

This section applies only to data collected via the Scoreboard App.

Data Category: Account & Registration Data (Email, Hashed Password, Firebase UID)

  • Purpose of Processing: To create, secure, and manage your user account; authenticate logins; and provide access to features.
  • Legal Basis (GDPR): Art. 6(1)(b) – Performance of a Contract (Your agreement to our Terms & Conditions).

Data Category: Subscription & Transaction Data (Pro status, subscription ID, expiration date)

  • Purpose of Processing: To manage your “Pro” subscription status and verify purchases made through third-party payment gateways (Apple/Google). Note: We do not collect or store credit card details.
  • Legal Basis (GDPR): Art. 6(1)(b) – Performance of a Contract (Managing your paid subscription).

Data Category: App Usage Data (Local) (Saved scoreboards, game data, user settings)

  • Purpose of Processing: This data is stored exclusively on your device (local storage). We do not access, collect, or back up this data. Its management is your sole responsibility.
  • Legal Basis (GDPR): Not Applicable (Data is not processed by the Controller).

Data Category: Technical & Analytics Data (OS version, device ID, anonymous crash logs)

  • Purpose of Processing: To monitor the technical health of the App, diagnose and fix bugs, and analyze aggregated, non-identifiable usage trends.
  • Legal Basis (GDPR): Art. 6(1)(f) – Legitimate Interest (Ensuring the stability and optimization of our App).

5. Part C: Data Processing – SWISH FORCE® Statistics App (Forthcoming)

The SWISH FORCE® Statistics application is scheduled for a future release.

Upon its launch, this Policy will be updated to detail all specific data processing activities for this app, which may include the collection and cloud synchronization of performance metrics and game data, in addition to the data categories listed in Part B.

6. Data Recipients and Sharing (All Services)

SWISH FORCE® does not sell, rent, or lease your personal data. Your data is only shared with essential third-party service providers (“Data Processors”) necessary to operate our Services:

  • Firebase (Google LLC): User Authentication and secure Database Hosting (Cloud Firestore) for App accounts.
  • RevenueCat, Inc.: Subscription Management (App). Verifies Pro status and manages payment webhooks.
  • Apple App Store / Google Play: Payment Processing (App). These entities act as independent Data Controllers for the financial transaction.
  • Google Analytics: Website traffic analysis.

7. International Data Transfers

Our primary operations are within the European Union. However, the use of Firebase, RevenueCat, and Google Analytics involves the transfer of certain data to servers located in the United States of America. We ensure these transfers are lawful and secure by relying on approved GDPR safeguards, specifically the Standard Contractual Clauses (SCCs).

8. Data Retention and Security

Retention: We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected.

  • Account Data is retained for as long as your account is active.
  • Support Data is retained for a maximum of 2 years after resolution.

Security: We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, or destruction. This includes using secure authentication (Firebase) and SSL/TLS encryption.

9. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Any changes will be posted on this page and, if significant, we will provide a more prominent notice (such as an in-app notification).

10. App Store & Google Play — Data Safety Summary

This section provides a transparent summary for the Google Play Data Safety and Apple App Store privacy labels, based on our use of Firebase (Auth, Firestore, Analytics) and RevenueCat (Subscriptions).

Data Collected:

We have declared the following data types are “Collected”.

Category Data Type(s) Usage Purpose(s) Required?
Personal Info Email address, User IDs (Firebase UID, RevenueCat ID) App functionality, Account management No (Optional, for Pro features)
Financial Info Purchase history (via RevenueCat) App functionality, Analytics, Account management No (Optional, for Pro features)
App Activity App interactions (Analytics), Crash logs, Diagnostics, Other performance data Analytics Yes (Analytics & crash logs are required for app stability)
Device & IDs Device or other IDs (Instance IDs) App functionality, Analytics, Account management Yes (Required for app functionality)

Security & Deletion:

  • Data Sharing: We do NOT “Share” any collected data with third parties for tracking or advertising purposes. Data is only “Collected” and used by us (the Controller) via our service providers (Processors).
  • Tracking: The app does NOT track users across apps and websites owned by other companies.
  • Encryption: All data is encrypted in transit (using SSL/TLS).
  • Data Deletion: Users may request account and associated data deletion by contacting us at support@swishforce.com.

11. Exercising Your Rights & Data Requests

To request access, correction, deletion, portability or restriction, contact: support@swishforce.com. Provide sufficient information to identify your records (account email or Firebase UID if known). We will respond within applicable legal timelines.

12. Changes to This Policy

We may update this Policy. Substantial changes will be communicated via the app or on the website. The date at the top of this page reflects the latest revision.

Last Updated: November 15, 2025