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 Cloud: the owner's account, Hobby plan, EU region, live since 2026-10-02. It sets no cookies and stores no IP addresses. Data is processed by Umami Software, the service provider, in the EU region. It will also be used on the working stand (app.useswage.com) later, with job URLs anonymised to /job/:id and downloads not tracked.
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_ask does 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, cancelling a job deletes the file immediately, and unsubscribing from the newsletter works through a 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.