This Privacy Policy explains how StudioIndex - F.Z.C (Registration Number: 43943), operating Swokei ("Swokei", "we", "us", or "our"), collects, uses, stores, and shares personal data when you use our website, application, and related services.
By using Swokei, you acknowledge this Privacy Policy.
1. Who We Are
Swokei is operated by:
StudioIndex - F.Z.C
Registration Number: 43943
Contact email: [email protected]
If you have any privacy-related questions, you can contact us at the email above.
This policy covers the data of people who use Swokei, visit our website, or whose business details are in Swokei's business directory or in emails sent through Swokei (section 11). When our customers put their own leads and contacts into Swokei, the customer is the controller of that data and we process it for them as their processor, under our Data Processing Agreement.
2. Data We Collect
We may collect the following categories of personal data:
a. Account and contact information
This may include your name, email address, company name, billing details, and account credentials.
b. Service usage data
This may include login activity, feature usage, actions performed in the app, timestamps, browser type, device information, IP address, and diagnostic information.
When you are signed in to the app, we log how you use it so we can run, support and improve the service: the pages and windows you open, how long each is open, the buttons and links you click, and the last page you were on. We do not log what you type into fields. This log is tied to your account and kept for as long as your account exists.
On swokei.com itself we log each visit, so we can see how people find and use the site: the pages opened, how long each is open and how far it is scrolled, the buttons and links clicked, the homepage test, and the link followed into the app. This log stores nothing on your device (no cookie). If you create an account after that visit, the visit is joined to your account.
c. Content you provide
This may include website URLs, lists, prompts, generated text preferences, connected spreadsheet data, support messages, and other content you submit through the service.
d. Third-party integration data
If you connect Google Sheets or other supported services, we may receive account information and the specific data needed to provide the requested integration feature.
e. Payment and transaction data
If paid features are offered, payment-related information may be processed by our payment providers. We may receive limited transaction details such as payment status, subscription status, billing period, and invoice-related metadata, but we do not necessarily store full card details ourselves.
3. How We Use Personal Data
We may use personal data to:
- provide, operate, and maintain Swokei
- authenticate users and secure accounts
- process website analysis and generate automated output
- enable integrations and requested workflows
- provide customer support
- monitor performance, reliability, and abuse
- improve our service, features, and user experience
- process payments and manage subscriptions
- send service-related notices and important operational messages
- comply with legal obligations
- protect our rights, users, systems, and business
4. Legal Bases for Processing
Where applicable under the GDPR or similar laws, we rely on one or more of the following legal bases:
- Performance of a contract: where processing is necessary to provide the service you requested
- Legitimate interests: where processing is necessary for service improvement, security, fraud prevention, and business operations, provided those interests are not overridden by your rights
- Consent: where consent is required by law
- Legal obligation: where processing is required to comply with applicable law
5. Google API and Google Workspace Data
If you connect a Google account to Swokei, we only access the Google user data that is necessary to provide the feature you request, such as reading from or writing to a Google Sheet that you choose to connect.
We do not use Google user data for unrelated advertising purposes, and we do not sell Google user data.
The use of information received from Google Workspace APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
6. How We Share Data
We may share personal data with:
- hosting, infrastructure, and cloud providers
- analytics, logging, and security providers
- payment processors
- customer support tools
- integration providers that you choose to connect
- professional advisers where reasonably necessary
- regulators, authorities, or law enforcement where required by law
- a buyer, investor, or successor in connection with a merger, acquisition, financing, or sale of assets
The service providers we use, what each does and the data each receives are listed on our sub-processors page.
We do not sell personal data in the ordinary meaning of the term.
7. International Transfers
Because we may use service providers in different countries, your personal data may be processed outside your country of residence, including outside the European Economic Area.
StudioIndex - F.Z.C is established in the United Arab Emirates, and several of our providers process data in the United States. Where personal data from the European Economic Area, the United Kingdom or Switzerland is transferred to a country without an adequacy decision, we use the European Commission's Standard Contractual Clauses (with the UK International Data Transfer Addendum for UK data) or another transfer mechanism recognised by the applicable law.
8. Data Retention
We retain personal data for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:
- maintain your account
- provide the service
- comply with legal, tax, accounting, and regulatory obligations
- resolve disputes
- enforce our agreements
- improve service reliability and security
Retention periods may vary depending on the type of data and the reason we hold it.
When you delete your account in the app, it is deactivated straight away and permanently deleted after a 30-day grace period, during which you can change your mind. You can delete individual leads, contacts and campaigns at any time.
9. Security
We use reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, disclosure, alteration, and destruction.
However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
10. Your Rights
Depending on your location and applicable law, you may have the right to:
- access your personal data
- correct inaccurate personal data
- request deletion of your personal data
- restrict or object to certain processing
- request data portability
- withdraw consent where processing is based on consent
- lodge a complaint with a competent supervisory authority
To exercise applicable rights, contact us at [email protected]. You can also complain to the data protection supervisory authority in the country where you live or work, for example Datatilsynet in Norway.
11. Business Contacts in Our Directory and Recipients of Our Customers' Emails
This part of our privacy information is for people who have not signed up to Swokei: people whose business contact details are in Swokei's business directory, and people who receive an email that a Swokei customer sends through Swokei.
Who is responsible
StudioIndex - F.Z.C (Registration Number: 43943), which operates Swokei, is the controller of the business directory. You can reach us at [email protected].
If you received an email sent through Swokei, it was written and sent by a Swokei customer, from that customer's own mailbox and under their name. That customer decided to contact you and is the controller of their campaign. Swokei processes the data for them as their processor. You can contact the sender directly by replying to their email, or contact us.
What data we hold
- business details: business name, website, industry, business address and location, business email addresses and phone numbers
- where a business publishes them: the names and job titles of people at the business, and links to its public business profiles (for example LinkedIn, Facebook or Instagram)
- public ratings and review counts from map listings
- observations about the business's public website, such as screenshots and how it loads and displays
- if a customer emails you: the email, whether it was opened or a link was clicked if the sender turned tracking on, your reply, and whether you asked not to be contacted
We do not collect special categories of personal data, and the directory is meant to hold business contact details, not private ones.
Where it comes from
From publicly available sources: businesses' own websites (including through the Common Crawl public web archive), official business registers such as the Norwegian Register of Business Enterprises, open map data, and public business listings on map services. A customer may also have imported your details from their own sources.
Why we use it, and on what legal basis
Swokei helps businesses find other businesses that may need their services, look at their public website, and write to them one to one. We use the directory to let customers find businesses, and we process the data in a campaign to write, send and track those emails for the customer.
Our legal basis is legitimate interests (Article 6(1)(f) GDPR): our interest in offering a directory of businesses, and our customers' interest in contacting businesses about their services. We keep this to business contact details, and you can object at any time. Each customer who emails you is responsible for following the marketing rules of your country, including getting your consent first where the law requires it.
Who receives it
Swokei customers who search the directory or add you to a campaign, and the service providers listed on our sub-processors page, some of which are outside the European Economic Area. Those transfers are covered by the European Commission's Standard Contractual Clauses or another lawful transfer mechanism.
How long we keep it
Directory details are kept for as long as the listing is kept in the directory, and removed when you ask. Details in a customer's campaign are kept for as long as that customer keeps them in their account, and are deleted when they delete them or their account.
Your right to object, and your other rights
You can object at any time to your data being used for direct marketing, and we and our customers must stop. To do that:
- reply "no" or "stop" to any email sent through Swokei, and that sender will not write to you again
- or write to [email protected] with the email address or website concerned. We will remove your details from our directory so they are no longer offered to customers, and if you tell us which email you received, we will pass your objection on to the customer who sent it
You also have the right to ask for access to your data, to have it corrected or deleted, and to restrict how it is used. Write to [email protected].
You have the right to complain to a data protection supervisory authority, in particular the one in the country where you live or work (for example Datatilsynet in Norway, the ICO in the United Kingdom or the CNIL in France).
This section is also published on its own at swokei.com/privacy/recipients.
12. Children's Privacy
Swokei is not directed to children, and we do not knowingly collect personal data from children under the age required by applicable law to provide valid consent.
If you believe a child has provided us with personal data, contact us and we will take appropriate steps.
13. Cookies and Similar Technologies
Swokei may use cookies and similar technologies for authentication, security, preferences, analytics, and service functionality.
We ask for your consent before using non-essential cookies, on swokei.com and in the app, and both read the same choice. Our Cookie Policy lists every cookie and tool we use.
14. Third-Party Links and Services
Swokei may contain links to third-party websites or services. We are not responsible for the privacy, security, or content practices of third parties.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. If we make material changes, we may provide notice through the service or by other reasonable means.
The "Last updated" date at the top indicates when this Privacy Policy was most recently revised.
16. Contact
If you have questions or requests regarding this Privacy Policy or your personal data, contact:
StudioIndex - F.Z.C
Registration Number: 43943
Email: [email protected]