Swage Privacy Policy (public beta)
Draft.
Draft, not a legal opinion. The owner answers any regulator's questions or complaints himself as they come up.
1. Who processes the data
Operator: a sole proprietor (osek) registered in Israel. Contact for data questions: ask@useswage.com.
2. What data, why, for how long, on what legal basis
| Data | Purpose | Retention | Legal basis |
|---|---|---|---|
| The uploaded file and its content | Run the conversion job the user asked for | Deleted as soon as processing no longer needs it; the result no later than the job's retention period (default 24 hours) | performance of a request made by the user (GDPR art. 6(1)(b)) |
| E-mail address, if given to be notified a job is done | Send one e-mail when the job finishes | Stored with the job, deleted on the same schedule; never reaches the output | consent when the address is given; otherwise performance of the request |
| Text and optional contact in a "Send for review" report / "something's wrong" complaint | Study why reading the file failed | 30 days, then deleted | consent (an explicit user action) |
| Messages in the on-site chat | Reply to the user | 30 days, then deleted | consent |
| A file kept beyond the normal schedule, for studying a failure | Understand why a conversion failed | Until the study is done, then deleted | explicit, separate consent for each such case |
| Anonymised statistics (job count, formats, object counts, verification outcome) | Understand load and quality; not linked to any file or user | Not tied to the source data; no separate time limit | legitimate interest in operating the service |
swage_ask cookie | Avoid asking for a review on the same job more than once per 30 days; holds no e-mail, job number, or name | Until the cookie expires | legitimate interest / strictly necessary function |
| Admin login session cookie | Tell a signed-in administrator apart from an ordinary visitor | For the session's duration | legitimate interest of the operator |
Note: a planned newsletter (e-mail for project news) is covered on the RU side, docs/legal/PRIVACY-ru.md — it is not live for useswage.com yet.
What is not collected: the service does not process payment — the donate button, when configured, links to a third-party address; there are no accounts or passwords.
3. What the service does NOT do with your data
- Does not use the uploaded file for anything beyond the job you requested.
- Does not pass the file or its derivatives to third parties.
- Does not train models on the file. What the service learns is general layer- and field-matching rules, and only once they are confirmed by statistics across many files; the user's own data never becomes part of a rule.
- A file kept to study a failed read is kept only with the user's separate permission and deleted once the study is done.
4. Data transfers
- Data is not shared with third parties beyond the technical processors that run the service (hosting, mail delivery).
5. Cookies
Checked against the code on 2026-10-01:
- This EN landing page uses Umami, self-hosted and
cookieless — no personal data is stored, no cookie, no banner
(needs
UMAMI_SRC/UMAMI_IDset at build time or there is no script at all). - The RU landing page is covered separately in docs/legal/PRIVACY-ru.md — it uses Yandex.Metrica behind a consent banner, which EN visitors do not see.
- The working stand (the job page) sets two cookies:
swage_ask— technical, no personal data, and an admin login session cookie — only for a signed-in administrator. - No advertising cookies are set anywhere.
swage_askdoes not need its own consent banner: it carries no personal data, is never used for tracking or advertising, and serves one narrow purpose (not asking for a review on the same job more than once per 30 days).
6. Your rights
You may: find out what data about you is processed; ask for it to be corrected or deleted; withdraw consent (for example, cancel a job — the file is deleted immediately; unsubscribe from the newsletter — a working link in every e-mail, once that feature is live); object to processing; for EU users, data portability and the right to lodge a complaint with a supervisory authority.
Because the service keeps no accounts, most of these rights are already met automatically by the retention schedule. For a request outside that schedule, contact ask@useswage.com.
7. GDPR specifics
- Applicability. The service, offered to users in the EU, falls under GDPR by art. 3(2) regardless of the beta being free.
- Lawful basis for the newsletter. Consent (art. 6(1)(a)): a separate, unticked checkbox, a working unsubscribe link in every e-mail, no bundling with any other consent or with these terms.
- Representative. No EU representative is appointed yet. The service processes EU users' data as an ongoing part of a regularly offered service, not occasionally, so the "occasional processing" exemption under art. 27(2)(a) is unlikely to apply; appointing a representative is a pending administrative step.
- Processor agreements. On request, for a business customer whose files contain third-party personal data, the operator will sign a separate, reasonable data-processing agreement.
- Users in Russia are additionally covered by Russian law (152-FZ).
8. Changes to this policy
This policy may be updated as the service develops. The date of the last change is shown at the top.
9. Contact
For data questions: ask@useswage.com.