swim> portal ("we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, game servers, and services (collectively, the "Service").

Please read this Privacy Policy carefully. By using the Service, you agree to the collection and use of information in accordance with this policy.

Data Controller

Ursi Helvetia LLC is the data controller responsible for your personal data. For privacy-related inquiries, you may contact us at r@swimteam.nyc.

1. Information We Collect

1.1 Information We Store

We store minimal information necessary to operate the Service:

• Email address (received from your authentication provider)
• Linked account identifiers (Discord ID, Steam ID) if you choose to link these accounts
• Forum content you post (posts, threads, comments)
• Subscription status and tier (we store only Paddle reference IDs—not payment details, card numbers, or billing addresses)

We do not store:

• Passwords (handled entirely by our authentication provider)
• Payment card details, CVVs, or billing addresses (handled entirely by Paddle)
• Transaction amounts or invoices (stored by Paddle as Merchant of Record)

1.2 Information from Third-Party Services

When you link your account with third-party services, we store only the identifiers needed to maintain the link:

• Discord: User ID only
• Steam: Steam ID only

These third-party services may collect additional information under their own privacy policies. We encourage you to review the privacy practices of Discord, Steam, and any authentication providers you use.

1.3 Game Server Data

Our game servers collect and store:

• Connection data (IP address, connection times)
• In-game chat messages
• Gameplay statistics and activity
• Player identifiers (Steam ID, in-game name)

Game server data is stored separately from the portal website database.

1.4 Information Processed but Not Stored

The following information may be processed temporarily on the portal website but is not permanently stored:

• Session data (temporary, expires automatically)
• Standard web server logs (IP addresses, browser information)

2. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the Service
• Process transactions and manage subscriptions
• Send administrative messages and updates
• Respond to your comments and questions
• Monitor and analyze usage patterns
• Detect, prevent, and address fraud, abuse, and technical issues
• Enforce our Terms of Service and community guidelines
• Personalize your experience

2.1 Legal Bases for Processing (GDPR)

If you are located in the European Economic Area (EEA) or United Kingdom, we process your personal data under the following legal bases:

• Contractual Necessity: To provide our Service, manage your account, and process subscriptions as part of our agreement with you.
• Legitimate Interests: For security, fraud prevention, analytics, and improving the Service, where these interests are not overridden by your rights.
• Consent: For optional features, marketing communications, and non-essential cookies where consent is required by law.
• Legal Obligations: To comply with applicable laws, such as tax reporting and responding to lawful requests.

3. Sharing of Information

We may share your information in the following circumstances:

3.1 Service Providers

We share information with third-party service providers who perform services on our behalf:

• Paddle (payment processing and subscription management)
• Authentication providers (identity verification)
• Hosting providers (data storage and server infrastructure)

3.2 Legal Requirements

We may disclose your information if required by law or in response to valid requests by public authorities (e.g., court orders, government requests).

3.3 Protection of Rights

We may disclose information to protect the rights, property, or safety of swim> portal, our users, or others.

3.4 Public Content

Information you post publicly on forums or in game chat is visible to other users and the public. Once content is made public, we cannot control its further use, copying, or redistribution by others. Please exercise caution when sharing personal information in public areas of the Service.

4. Data Retention

We retain your personal data for as long as your account is active or as needed to provide you the Service:

• Portal account data (email, linked IDs): Retained while your account is active; deleted upon account deletion request
• Subscription references: Retained while your subscription is active; Paddle retains full transaction records as Merchant of Record per their retention policies
• Forum content: Retained unless deleted by you or removed for policy violations
• Game server logs and chat: Retained for operational and moderation purposes
• Session data: Automatically expires and is deleted

Upon account deletion, we will remove your personal data from the portal database. Game server logs may be retained separately for moderation and operational purposes. Certain records may also be retained by our third-party service providers (Paddle, authentication providers) per their own retention policies and legal obligations.

5. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

6. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Access: Request a copy of your personal data
• Correction: Request correction of inaccurate data
• Deletion: Request deletion of your personal data
• Portability: Request transfer of your data in a structured format
• Objection: Object to certain processing of your data
• Restriction: Request restriction of processing in certain circumstances
• Withdrawal: Withdraw consent where processing is based on consent

To exercise these rights, please contact us at r@swimteam.nyc. We may need to verify your identity before processing your request to protect your privacy and prevent fraud. We will respond to valid requests within 30 days (or as required by applicable law). In some cases, we may need additional time, and we will inform you if an extension is necessary.

Please note that certain rights may be limited by applicable law—for example, we may not be able to delete data we are required to retain for legal or compliance purposes.

7. Cookies and Similar Technologies

We use cookies and similar technologies for the following purposes:

7.1 Essential Cookies

These cookies are strictly necessary for the Service to function and cannot be disabled. They include session cookies for authentication and security.

7.2 Functional Cookies

These cookies remember your preferences and settings to enhance your experience.

7.3 Analytics Cookies

We may use analytics cookies to understand how users interact with the Service, helping us improve functionality and performance. Where required by law (such as in the EU/UK), we will obtain your consent before placing non-essential analytics cookies.

You can control cookies through your browser settings or, where applicable, through our cookie preferences. Disabling certain cookies may affect the functionality of the Service. Essential cookies cannot be disabled as they are required for core functionality.

8. Third-Party Links and Services

The Service may contain links to third-party websites or integrate with third-party services (Discord, Steam). We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

9. Children's Privacy

The Service is not intended for children under 13 years of age. We do not knowingly collect personal data from children under 13. If we become aware that we have collected data from a child under 13, we will take steps to delete such information.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States, where our servers and service providers are located. These countries may have different data protection laws than your home country.

For transfers from the EEA or UK, we rely on appropriate safeguards, including standard contractual clauses approved by the European Commission and contractual protections with our service providers. Our payment processor, Paddle, maintains its own data transfer mechanisms in compliance with applicable law.

By using the Service, you acknowledge that your data will be processed in the United States and other jurisdictions as described in this policy.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new Privacy Policy on this page, updating the "Last updated" date, and, where appropriate, notifying you by email or through an in-app notification.

We encourage you to review this Privacy Policy periodically. Your continued use of the Service after any changes constitutes acceptance of the updated policy.

12. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

• Email: r@swimteam.nyc
• Discord: romedius

swim> portal is operated by Ursi Helvetia LLC.