OBJECTIVE
In order to strengthen the concepts of transparency and simplicity that guide our work and to reaffirm our commitment to good business practices, Swap One Payments and Swap One Brazil (jointly, “Swap One”) have developed this Privacy Policy (“Policy”), in order to allow you to know how your personal data is treated due to the services contracted.
This Policy broadly covers the processing of personal data relating to:
- foreign exchange transactions carried out through partner financial institutions, including the foreign exchange matching model conducted by Swap One Brazil, when applicable; and
- services provided directly by Swap One Payments, including international payments and other financial services provided on its own account, as a regulated company in Canada.
INTRODUCTION
By using and contracting our services you declare that you are aware of and agree to the processing of your personal data, authorizing us to process it in accordance with the specifications, laws and appropriate standards applicable.
This Policy does not replace or invalidate the specific Data Processing Policy applied by Swap One.
Please read this Privacy Policy carefully and, if you have any questions, contact one of our communication channels available on our website: https://swapone.global.
CONCEPTS
Client(s): natural or legal persons who comply with the relevant regulations and can contract services and products made available and offered by Swap One;
Collaborator(s): employee(s) with a direct or indirect contractual relationship, who fulfill(s) the legal requirements for this characteristic, of those interested in the relationship between Swap One and its Client(s);
Foreign Exchange Correspondent(s): specific legal entity(ies) acting on behalf of and for the account and order of financial institutions, in accordance with Resolution No. 4,935/2021 and subsequent pertinent amendments, all of the National Monetary Council (“CMN”), which may collect data and offer services under the guidelines of the financial institutions through which it operates, as contracted and informed to the Central Bank of Brazil. Swap One Brazil may act, when applicable, as a foreign exchange correspondent or in an equivalent model through partnerships;
Commercial partners: these are financial institutions abroad and/or payment partners, contracted by Swap One Payments and/or Swap One Brazil (depending on the flow and service), through which remittances, international payments and/or cross-border settlements are made to the recipients informed and identified by the Clients;
Service Providers: natural or legal persons who provide specialized and dedicated services to Swap One or to Users and Clients for the contracted purpose.
User: the person who accesses the Swap One website.
FINTRAC: Financial Transactions and Reports Analysis Centre of Canada, the Canadian body responsible for the supervision and guidelines applicable to certain money services activities. Swap One Payments operates in Canada as an entity regulated by FINTRAC, where applicable.
SERVICES OFFERED
Swap One offers services for the facilitation and execution of financial and foreign exchange transactions, including, as applicable:
- acting through partner financial institutions and/or matching arrangements, where applicable, including activities conducted by Swap One Brazil, under the terms of the relevant regulations; and
- the provision, for its own account, of international payment services and other related services conducted by Swap One Payments, as a regulated entity in Canada, including when necessary to enable cross-border remittances, receipts and settlements.
The above description should be interpreted broadly and in line with the transnational nature of the operations, which may involve financial institutions, payment partners and technology and compliance service providers.
DATA COLLECTION AND PROCESSING – CONCEPTS AND PURPOSE
The data is collected when the user or client accesses the Swap One website. From that moment on, the data is collected so that a registration can be opened, so that the user or client can contract the services made available by Swap One.
DATA PROCESSING
It means any movement made with personal data, including the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction of such data.
DATA COLLECTED
Swap One only collects data that is essential for opening a registration, account and contracting the services provided.
The data collected are:
(i) those used for identification (full name, legally accepted identification documents, identity card, date of birth, full address, e-mail address, telephone number and mother’s name);
(ii) financial data including the bank with which the data subject has an account;
(iii) technical data such as your IP address, time and date of access, geolocation, data about your access device and cookies;
(iv) Usage data or information about how you use our services, profile, among others; and,
(v)biometric data, such as photos and personal documents for records.
The above personal data is the minimum required and complies with the regulations applicable to the activities and services provided.
PURPOSE
Your personal data is collected solely and exclusively for the purpose of: enabling registration analysis, opening accounts, offering and contracting services, complying with legal and regulatory obligations (including obligations to prevent money laundering, combat terrorist financing and sanctions, where applicable), managing relationship improvement, communicating with the client, sending and receiving digital communications (the client may choose to continue or stop receiving messages), as well as improving the experience between the client and Swap One.
AUTHORIZATIONS GRANTED
From the moment you access the Swap One page or website, you are expressly granting authorization for Swap One to collect your data (already mentioned and identified above), in order for the services and operations to be contracted regularly and within the legal standards required by the competent authorities and applicable regulators.
DATA SHARING
Swap One may share your personal data with its partners, financial institutions and/or payment partners with which it operates (including for the execution of international payments and settlements), legally and duly contracted service providers, affiliated entities or their subsidiaries, in particular.
It also works with statistical and search engine analysis providers to help improve and optimize Swap One’s website and services.
Finally, with supervisory or regulatory bodies in order to comply with judicial, legal, normative and regulatory orders or determinations, as well as with other institutions in order to carry out the contracting required by the Client, including the exchange of information with other companies and entities for the purposes of protection and prevention against fraud, risk reduction and mitigation.
SHARING PERSONAL DATA WITH INTERNATIONAL INSTITUTIONS
Swap One may transfer your personal data to financial institutions and/or payment partners, who may transfer it internationally, exclusively to provide their services and meet your demand, due to the fact that foreign exchange and international payment activities are transnational.
However, when this occurs, this data transfer will always take place with the maximum protection and security required and available on the market. In addition, data will only be transferred to countries or international organizations that legally have adequate security and data protection, always in accordance with the contractual clauses and conditions in the same terms agreed with and by Swap One.
STORAGE TIME
Personal data will be stored and kept for the period required by laws and regulations applicable to the activities of Swap One and/or its partners, including for the purposes of auditing, fraud prevention and responding to requests from competent authorities.
SAFETY STANDARDS
Swap One always uses, hires and makes available the highest standards of IT security found on the market. Furthermore, it always adopts and establishes standards and guidelines with the utmost seriousness and discloses them in accordance with its policies. Finally, it complies and remains compliant with the laws, rules and regulations applicable to its activities and services.
Swap One employees who carry out any data processing are subject to a specific Confidentiality Agreement, in order to comply faithfully with the applicable legal and regulatory provisions.
WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?
Swap One customers, as the owners of their personal data, have the right to access their data, requesting a copy, clarification, criteria used, purpose, review, alteration, deletion, portability and anonymization (the latter, where applicable).
Customers can also request to oppose the processing of their data if it is not processed in the express terms for which they consented.
In addition, they can request the deletion or exclusion of their data, which will be carried out in compliance with the legal regulations of the regulatory bodies and their established deadlines.
COOKIES
Cookies are small packets of data that a web server stores on your computer’s hard disk or access tool, allowing it to remember information about your visit. They appear as text structures inserted into your electronic device, enabling the website and the system that supports it to function and improve your browsing experience.
Swap One may use cookies that expire as soon as you close your browser or may use cookies that remain until you delete them yourself.
The cookies used and when used are always those that provide security and protection for your operations and contracts with Swap One.
Cookies are subject to the same guidelines set out in the General Data Protection Act, in accordance with the terms of this Privacy Policy.
FINAL PROVISIONS
The User or Client, by continuing with the contracting of services made available by Swap One, declares that he/she has read, understood and expressly accepts the terms of this Privacy Policy, as well as agrees, authorizes and consents to Swap One, when applicable, collecting his/her information for the express purposes stated above.
If you do not agree or do not accept any of the terms of this Policy, please direct your points to the e-mail address and only after a reply from our team, clarifying your doubts, proceed with your hiring.
This Policy does not replace or invalidate the Data Processing Policy which is specific to establishing the rules and disclosing information on data and its processing, which is available and can be accessed on the Swap One website.
The Review and Maintenance of this Policy is the responsibility of the Compliance Department, set up and led by the Swap One management body, and will be carried out whenever the need to update the provisions contained in this instrument is detected.
The analysis must include and take into account both the internal and external environments with which Swap One relates.
Last revision: 31/03/2026.