Privacy Policy

Introduction and Scope

• This Privacy Policy explains how RetroSwap collects, uses, and protects personal information when you use our website, software, integrations, and related services.
• RetroSwap is operated by Cognitivv Inc., 169 Madison Ave STE 2930, New York, NY 10016, which acts as the data controller for personal information covered by this policy.
• This policy applies to visitors, account owners, staff users, and people who communicate with us about the service.
• If a separate contract, data processing addendum, or integration agreement applies, that document may supplement this policy for that relationship.

Information We Collect

Sources of Information

• Directly from you when you create an account, configure your workspace, connect integrations, transact, or contact us.
• Automatically through cookies and similar technologies, logs, and instrumentation when you use our website and services.
• From connected third-party services that you authorize us to access.
• From service providers and partners that support security, payments, analytics, communications, and operations.

How We Use Information

• Provide, maintain, and personalize RetroSwap services and account functionality.
• Process subscriptions, billing, payment operations, and service provisioning.
• Operate security controls, detect fraud/abuse, and investigate incidents.
• Monitor performance, diagnose issues, and improve reliability and usability.
• Respond to support requests and account administration needs.
• Send transactional and service-related notifications.
• Send marketing communications where allowed, with opt-out controls.
• Evaluate AI output quality, investigate inaccurate outputs, and improve model-assisted product behavior using submitted feedback signals.
• Comply with legal obligations and enforce agreements and platform policies.

AI-Assisted Features and Accuracy

• Some RetroSwap features use AI to generate suggestions, classifications, summaries, and other assistive outputs.
• AI outputs may be incorrect, incomplete, or outdated and should not be treated as guaranteed factual determinations.
• You are responsible for human review and independent verification before relying on AI output for pricing, authenticity, legal, compliance, tax, accounting, or customer-impacting decisions.
• When you submit AI feedback (for example thumbs up/down and notes), we may use that information to audit, improve, and monitor AI-assisted features.

Legal Bases for Processing (EEA/UK)

• Contract necessity: to provide the services you request and manage your account.
• Legitimate interests: to secure, maintain, and improve our services and prevent abuse.
• Legal obligations: to meet tax, accounting, regulatory, and law-enforcement requirements.
• Consent: where required, including certain marketing or non-essential tracking activities.

Cookies and Similar Technologies

• We use cookies and similar technologies to run the service, analyze usage, and support marketing/attribution activities.
• You can control cookies through browser settings and available in-product controls.
• Disabling some cookies may reduce functionality, including authentication and performance features.

Sharing and Disclosure

• We share information with vendors and service providers that support hosting, analytics, payments, communications, and operations.
• We may share data with integrations and third-party services when you direct or authorize those connections.
• We may disclose information to comply with law, legal process, or valid governmental requests.
• We may disclose information to protect rights, safety, security, and prevent fraud or abuse.
• Information may be disclosed in connection with mergers, acquisitions, financing, or similar corporate transactions.
• We do not sell personal information and we do not share personal information for cross-context behavioral advertising.

International Data Transfers

• Personal information may be processed in countries outside your jurisdiction.
• Where required, we use contractual and organizational safeguards designed to protect personal information during cross-border transfers.
• Transfer mechanisms and protections are applied in a manner intended to support applicable privacy laws.

Data Retention

• We retain personal information only as long as necessary for the purposes described in this policy unless a longer period is required or permitted by law.
• Retention periods may be extended when needed for legal claims, dispute resolution, audits, fraud prevention, and regulatory obligations.

Your Privacy Rights

• Depending on your location, you may have rights to access, correct, delete, or receive a copy of your personal information.
• You may also have rights to object to or restrict certain processing, request data portability, or withdraw consent where processing is based on consent.
• Residents in the EEA/UK may lodge complaints with a supervisory authority.
• Residents in US states with privacy laws may have rights to know, delete, correct, and receive data portability, subject to legal exceptions.
• We do not discriminate against users for exercising applicable privacy rights.
• To exercise rights, contact support@retroswap.com. We may verify identity before processing requests and may offer an appeal process where required.

California and US State Disclosures

• Categories of personal information we collect include identifiers, commercial information, internet/activity data, geolocation-derived data (such as IP-based location), and communications content you provide.
• We collect and use these categories for operational, security, analytics, support, legal compliance, and service delivery purposes described in this policy.
• We disclose these categories to service providers/processors and authorized integration partners as needed to operate the service.
• We do not sell personal information and we do not share personal information for cross-context behavioral advertising.
• Authorized agents may submit requests on your behalf where permitted by law, subject to verification requirements.
• If your request is denied and local law provides appeal rights, you may submit an appeal via support@retroswap.com.

Marketing Communications

• You can opt out of non-essential marketing emails at any time using unsubscribe links or by contacting us.
• We may still send essential transactional or service notifications (for example security, billing, and account notices).

Security

• We use administrative, technical, and organizational safeguards designed to protect personal information.
• No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
• You are responsible for safeguarding credentials and notifying us promptly of suspected unauthorized access.

Children's Privacy

• Our services are not directed to children under 13, and we do not knowingly collect personal information from children under 13.
• If we become aware that personal information from a child under 13 has been collected without proper authorization, we will take steps to delete or appropriately handle that information.
• Parents or guardians who believe we may have collected such information can contact us at support@retroswap.com.

Third-Party Links and Services

• Our services may include links to third-party websites, products, or services that are not controlled by us.
• This Privacy Policy does not apply to third-party privacy practices, and you should review their policies separately.

Changes to This Policy

• We may update this Privacy Policy from time to time to reflect product, legal, or operational changes.
• When we update this policy, we will revise the "Last updated" date above.
• For material changes, we may provide additional notice through the service or other reasonable channels.

Contact Information

• Data controller: Cognitivv Inc.
• Address: 169 Madison Ave STE 2930, New York, NY 10016.
• Privacy contact: support@retroswap.com.
• Data Protection Officer (DPO): None designated.