Privacy Policy

1. Who we are

Swiback Limited is a company incorporated in Hong Kong. We provide confidential strategic advisory services. Swiback is the controller responsible for the personal data described in this policy. For any privacy matter, contact us at privacy@swiback.com.

2. Scope

This policy explains how we handle personal data collected through swiback.com. We work by referral and collect only the data needed to respond to enquiries.

3. What we collect

Information you provide through the contact form: your name, your email address, and the content of your message.

Technical data: when you visit the site, our hosting provider records standard server log data, including your IP address, to keep the service running and secure. The contact form uses your IP address only to prevent automated abuse.

We do not use tracking cookies, and the site has no advertising or visitor-measurement service.

4. Why we use it, and on what basis

To respond to your enquiry and take steps at your request before any engagement. Basis: steps taken at your request prior to a possible engagement, and our legitimate interest in responding to qualified approaches.

To keep the site secure and prevent abuse. Basis: our legitimate interest in the integrity of the service.

5. Who has access

Your data is hosted and transmitted through Infomaniak, our hosting and email provider, whose infrastructure is located in Switzerland. Infomaniak acts on our instructions as a processor. We do not sell your data, and we do not share it with third parties for their own purposes.

6. International transfer

Swiback is established in Hong Kong. When we read and answer your enquiry, your data is accessed from Hong Kong, which is outside the European Economic Area and is not covered by a European adequacy decision. Where you contact us from the European Economic Area or Switzerland, this transfer takes place because it is necessary to respond to your enquiry and to take steps at your request, and on the basis of your consent when you submit the form. We keep such transfers limited to what is needed to handle your enquiry.

7. How long we keep it

We keep enquiry correspondence for up to 24 months after our last exchange, then delete it, unless a longer period is required to meet a legal obligation or to establish or defend a legal claim. We do not store enquiries in a database.

8. Your rights

Subject to applicable law, you may request access to your data, its correction or deletion, the restriction of its processing, and you may object to processing. Where processing relies on consent, you may withdraw that consent at any time. To exercise any right, write to privacy@swiback.com. You may also lodge a complaint with a data protection authority: in the European Economic Area, your national authority; in Switzerland, the Federal Data Protection and Information Commissioner; in Hong Kong, the Office of the Privacy Commissioner for Personal Data.

9. Security

We limit collection to what is necessary, transmit data over encrypted connections, and do not keep it beyond the period stated above.

10. Changes

We may update this policy. The date at the top shows the current version.