Privacy Policy
Last Updated: March 2026
This Privacy Policy explains how Majerszki Nikolett E.V. (“we,” “us,” or “our”) collects, uses, discloses, and protects your personal data and explains your privacy rights.
For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other applicable data protection laws, the data controller is:
Majerszki Nikolett E.V. (sole proprietor)
Country: Hungary
Tax number: 55861362130
Sole proprietor registration number: 54603222
This Privacy Policy applies to our website, mobile applications, and related services (collectively, the “Services”).
1. SCOPE AND UPDATES TO THIS PRIVACY POLICY
This Privacy Policy applies to personal data processed by us, including through our home swapping services (“Home Swapping Services”), websites, mobile applications, and other online or offline offerings. To make this Privacy Policy easier to read, our Home Swapping Services, websites, mobile applications, and other offerings are collectively called the “Services.”
Changes to our Privacy Policy
We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law (for example, by posting a notice within the Services, by email, or by other appropriate means). Unless otherwise required by law, the updated Privacy Policy will be effective as of the “Last Updated” date above. By continuing to use the Services after the updated Privacy Policy becomes effective, you acknowledge the updated Privacy Policy.
2. PERSONAL DATA WE COLLECT
The categories of personal data we collect depend on how you interact with us, the Services, and the requirements of applicable law. We collect: (i) personal data you provide directly to us; (ii) personal data we collect automatically when you use the Services; and (iii) personal data from other sources such as third-party services and organizations, as described below.
A. Personal Data You Provide to Us Directly
We may collect personal data that you provide to us, including:
Account Administration
If you register with us to become a member of the community or join our Slack channel (a “Member”), we may collect personal data in connection with the application and administration of your account, such as: Name, Email address, Phone number, Physical address, Employment background, Username/display name, Profile and other pictures, Photos of your home, Your home’s availability, and other information about you or your home that you choose to provide.
Purchases or Transactions
We may collect personal data and details about your purchases or transactions, including payment-related information. Payments made via the Services are processed by third-party payment processors. We do not directly collect or store full payment card information entered through our Services, but we may receive limited information associated with your payment (e.g., billing details, payment confirmation, and transaction identifiers).
Your Communications with Us
We may collect personal data, such as email address, phone number, or mailing address when you request information about our Services, register for newsletters, request concierge or technical support, use our Slack channel, apply for a job, or otherwise communicate with us.
Surveys
We may contact you to participate in surveys. If you decide to participate, we may collect personal data from you in connection with the survey.
Interactive Features
We and others who use our Services may collect personal data that you submit or make available through interactive features (e.g., messaging and chat features, commenting functionality, forums, blogs, Slack, and social media pages). Any information you provide using public sharing features of the Services will be considered “public” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
Sweepstakes or Contests
We may collect personal data you provide for sweepstakes or contests that we offer. In some jurisdictions, we may be required to publicly share information about sweepstakes and contest winners.
Conferences, Trade Shows, and Other Events
We may collect personal data when we attend or host conferences, trade shows, and other events.
Business Development and Strategic Partnerships
We may collect personal data from individuals and third parties to assess and pursue potential business opportunities.
Job Applications
We may post job openings on our Services. If you respond, we may collect personal data such as your application, CV/resume, cover letter, and any other information you provide to us.
B. Personal Data Collected Automatically
We may collect personal data automatically when you use our Services.
Automatic Collection
We may collect certain information automatically, such as: Internet protocol (IP) address, User settings, MAC address, Cookie identifiers, Mobile carrier, Mobile advertising identifiers and other unique identifiers, Browser or device information, Location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of the Services, such as pages visited before, during, and after using the Services; links clicked; types of content interacted with; frequency and duration of activities; and other information about how you use the Services.
Cookie Policy (and Other Technologies)
We and third parties that provide content, advertising, or other functionality on our Services may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
Cookies. Small text files placed in device browsers that store preferences and facilitate and enhance your experience.
Pixel Tags/Web Beacons. Code embedded in our Services that collects information about engagement. Pixel tags allow us to record, for example, that a user visited a particular web page or clicked an advertisement. We may include web beacons in emails to understand whether messages were opened, acted on, or forwarded.
Our uses of these Technologies generally fall into these categories:
- Strictly Necessary / Operationally Necessary: Required for the Services to function, to authenticate users, to detect irregular behavior, prevent fraud, improve security, or enable core functionality.
- Performance / Analytics: Used to assess and improve the performance of our Services and understand how individuals use the Services.
- Functional: Used to remember preferences and enhance functionality (e.g., keeping you signed in).
- Advertising / Targeting: Used to deliver content and ads relevant to your interests on our Services or on third-party digital properties.
Consent for cookies: Where required by applicable law (including in the EEA/UK), we will request your consent before placing non-essential cookies/Technologies on your device, and you can change your preferences at any time via our cookie banner or settings.
Analytics
We may use Technologies and third-party tools to process analytics information. Google Analytics may collect information about your use of the Services. For more information, please review Google’s policies. You may be able to opt out of Google Analytics tracking through tools provided by Google or via our cookie settings (where applicable).
C. Personal Data Collected from Other Sources
Third-Party Services and Sources
We may obtain personal data about you from other sources, including third-party services and organizations. For example, if you access our Services through a third-party application (such as an app store), a third-party login service, or a social networking site, we may collect personal data made available via your privacy settings on that third party. We may ask you to provide consent to access information from your social media accounts (e.g., LinkedIn) to foster a more meaningful network among Members. We may receive fraud warnings from identity verification providers for use in fraud prevention and risk assessment. Where permitted by applicable laws, we may also engage vendors to conduct background checks in connection with trust and safety, fraud prevention, and risk assessment. We may receive your name, date of birth, address, and background-check results. Depending on the vendor and jurisdiction, the vendor may use relevant databases and reports to return results.
Stripe Identity
We use Stripe for identity document verification. Stripe may collect identity document images, facial images, ID numbers, addresses, advanced fraud signals, and information about the devices that connect to Stripe’s services. Stripe shares this information with us, and Stripe may also use this information to operate and improve the services it provides, including for fraud detection. Where available, you may also choose to allow Stripe to use your data to improve biometric verification technology. You can learn about Stripe and read its privacy policy at Stripe’s website.
Other Members or Applicants
Other Members may provide us with personal data about individuals associated with their use of the Services. For example, a Member may provide personal data about another Member or a non-member included in their home reservation. We may also ask applicants for the name of a Member or other person who recommended the Services.
Referrals and Sharing Features
Our Services may offer tools that allow you to provide personal data about friends, colleagues, or other contacts through referral features, including by sharing an email invitation. Please only share contact information of people with whom you have a trusted relationship and where you have a lawful basis to share such information.
3. HOW WE USE YOUR PERSONAL DATA
We use personal data for a variety of purposes, including to provide the Services, for administrative purposes, and for marketing, as described below.
A. Provide Our Services
We use your personal data to evaluate applications, perform our contract with you, and provide the Services, such as: Processing membership applications, including conducting identity verification and, where permitted by applicable law, background checks; Managing your information and accounts; Facilitating reciprocal and non-reciprocal swaps (“bookings”) based on Members’ availability; Providing access to areas, functionalities, and features of the Services; Providing concierge or technical support; Communicating with you about your membership, account, activity, and policy changes; Processing financial information and other payment methods for purchases; Processing job applications; Allowing you to register for events.
B. Administrative Purposes
We use personal data for administrative purposes, such as: Pursuing legitimate interests (e.g., direct marketing where permitted, research and development, network and information security, fraud prevention); Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity; Measuring interest and engagement; Improving, upgrading, and enhancing the Services; Developing new products and services; Ensuring internal quality control and safety; Authenticating and verifying identities, including in response to privacy-rights requests; Debugging and repairing errors; Auditing related to interactions, transactions, and compliance activities; Sharing personal data with third parties as needed to provide the Services; Enforcing agreements and policies; Complying with legal obligations.
C. Marketing and Advertising
We may use personal data to tailor and provide content and advertisements, as permitted by applicable law. Marketing may include email campaigns, text messages, custom audience advertising, and interest-based advertising, including across-device tracking, where permitted and subject to your preferences/consent. If you have questions about our marketing practices, contact us as described in “Contact Us” below.
D. With Your Consent
We may use personal data for other purposes that are clearly disclosed at the time you provide the data, with your consent, or at your direction.
E. Other Purposes
We also use personal data for other purposes requested by you or permitted by applicable law.
De-identified and Aggregated Information: We may create de-identified and/or aggregated information (e.g., generalized location or demographic insights, device-level insights, analytics). This information is not personal data and may be used and disclosed for research, analytics, internal analysis, and other legally permissible purposes.
4. HOW WE DISCLOSE YOUR PERSONAL DATA
We disclose personal data to third parties for business purposes, including to provide the Services, protect us or others, and in connection with major business transactions.
A. Disclosures to Provide our Services
We may share personal data with the following categories of recipients:
- Members: Accepted Members’ homes may be featured in the app with photos, availability, the Member’s first name, profile picture, job description, approximate geographic location, and home features/amenities. We may also disclose personal data to other Members in other ways. For example, if you are a Guest or a Host, we may share personal data with the Host or Guest (as applicable) to identify bookings, facilitate bookings, resolve disputes, or promote other interactions. Hosts may also collect personal data from you when you are a Guest in a Host’s home. This Privacy Policy does not cover other Members’ processing of your personal data, and we are not responsible for their practices.
- Service Providers: We may share personal data with third-party service providers that help us provide the Services, such as IT support, hosting, payment processing, customer service, ID verification, background checks, analytics, communications tooling, and similar vendors. These providers act as processors where applicable and are subject to contractual obligations.
- Third-Party Services: We may disclose personal data to third-party services (“Third-Party Services”) you choose to connect, share with, or otherwise interact with.
- Business Partners: We may share personal data with business partners to provide a product or service you request, and with partners with whom we jointly offer products or services.
- Affiliates: We may share personal data with our affiliates (entities under common ownership or control), consistent with this Privacy Policy.
- Advertising Partners: We may share personal data with advertising partners. These partners may set Technologies on our Services to collect information about your activity and device (e.g., IP address, cookie IDs, pages visited, location, time of day). They may use this information (and similar information from other services) to deliver personalized advertising. Where required by law, we will do this only with your consent.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose information associated with you to external parties if we, in good faith, believe disclosure is required or appropriate to: Comply with law enforcement, national security requests, and legal process (e.g., court order or subpoena); Protect your, our, or others’ rights, property, or safety; Enforce policies or contracts; Collect amounts owed to us; Assist with investigations or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your personal data may be sold or transferred as part of that transaction, as permitted by law and/or contract.
5. YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices
Your choices depend on applicable law and are described below.
- Email Communications: If you receive an unwanted marketing email from us, you can use the unsubscribe link at the bottom of the email. You will still receive transactional/service emails related to the Services you requested. We may also send non-promotional messages necessary to operate the Services (e.g., policy updates), which you cannot opt out of.
- Text Messages: Where we send SMS, you may opt out by following the instructions in the message or by contacting us.
- Mobile Devices: We may send push notifications through our mobile application. You can opt out via your device settings. With your consent, we may collect precise location data via the app; you can opt out by changing device settings.
- Do Not Track: “Do Not Track” (“DNT”) is a browser preference. We do not respond to DNT signals.
- Cookies and Interest-Based Advertising: You can stop or restrict Technologies via your browser/device settings, and you can manage cookie consent through our cookie banner/settings where applicable. If you block certain cookies, parts of the Services may not function properly. Cookie-based opt-outs may not work in mobile applications. You may opt out of personalized ads on some mobile devices via platform settings. You must separately opt out on each browser and each device.
Your Privacy Rights (GDPR / UK GDPR)
If you are in the EEA, UK, or Switzerland, you have the right to: Access; Rectification; Erasure; Restriction; Data Portability; Object; Withdraw Consent. To exercise these rights, contact us as set forth in “Contact Us” below. We will respond in accordance with applicable law (generally within one month, subject to extensions where permitted).
Identity Verification for Rights Requests: We may need to verify your identity before responding to a request (e.g., confirming access to the email address on file), to protect your personal data.
Stripe Identity Retention: We use Stripe for identity verification. Stripe may retain data provided as part of verification. Where applicable, you may be able to request deletion or revoke consent through Stripe’s support channels and/or via our assistance, depending on your relationship with Stripe and the applicable process.
6. SECURITY OF YOUR INFORMATION
We take steps to help protect your personal data and process it securely in accordance with this Privacy Policy, including using appropriate technical and organizational measures. However, no system is 100% secure, and we cannot guarantee the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal data. By using the Services or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security breach, we may attempt to notify you electronically (e.g., by posting a notice, by email, or by other means) as required by law.
7. INTERNATIONAL DATA TRANSFERS
Personal data processed by us may be transferred, processed, and stored anywhere in the world, including the United States or other countries that may have data protection laws different from those where you reside. Where we transfer personal data from the EEA/UK/Switzerland to a country not deemed adequate by the relevant authority, we use appropriate safeguards, such as: EU Standard Contractual Clauses (SCCs) and/or the UK equivalent addendum; Additional technical and organizational measures where appropriate; Other lawful transfer mechanisms recognized by applicable law. For information about the safeguards we use, please contact us as set forth below.
8. RETENTION OF PERSONAL DATA
We store personal data for as long as you use the Services or as necessary to fulfill the purposes for which it was collected, including to: Provide the Services; Resolve disputes; Establish legal defenses; Conduct audits; Pursue legitimate business purposes; Enforce agreements; Comply with legal obligations. Retention periods may vary depending on the data type, purpose, and legal requirements. Where personal data is no longer needed, we securely delete, anonymize, or de-identify it.
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This section applies only if you are a California resident and the processing is subject to the California Consumer Privacy Act (“CCPA”) and its implementing regulations. California residents have the right to know what categories of personal information we collect and whether we disclose it for business purposes in the preceding 12 months.
| Categories of Personal Information Collected | Categories of Third Parties Disclosed to for Business Purposes |
|---|---|
| Identifiers | Members, Service Providers, Third-Party Services, Business Partners, Affiliates, Advertising Partners |
| Categories listed in Cal. Civ. Code § 1798.80(e) | Members, Service Providers, Third-Party Services, Business Partners, Affiliates, Advertising Partners |
| Protected classification characteristics | Members, Service Providers, Third-Party Services |
| Commercial information | Members, Service Providers, Advertising Partners |
| Internet or other electronic network activity | Service Providers, Advertising Partners |
| Sensory data | Members, Service Providers, Advertising Partners |
| Professional or employment-related information | Members, Service Providers |
| Inferences to create a profile | Service Providers, Advertising Partners |
The categories of sources and purposes are described above in Sections 2 and 3.
Additional Privacy Rights for California Residents
“Sale” of Personal Information: We do not “sell” personal information as defined by the CCPA, and we do not knowingly sell personal information of minors under 16. Non-Discrimination: You have the right not to receive discriminatory treatment for exercising CCPA rights. Authorized Agent: You may use an authorized agent to submit requests on your behalf. Verification: We will verify your identity and request before responding. De-Identified Information: If we create or receive de-identified information, we will not attempt to re-identify it except as permitted by law.
10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a Nevada resident, you may have the right to opt out of the sale of certain covered information to third parties who intend to license or sell that information. We do not currently sell your personal information as “sale” is defined under Nevada law. If you have questions, contact us as set forth below.
11. CHILDREN’S INFORMATION
The Services are not directed to children under 13 (or another age as required by local law), and we do not knowingly collect personal data from children. If you are a parent or guardian and believe your child has provided personal data without your consent, contact us as described below. If we become aware that a child provided personal data in violation of applicable law, we will delete it unless we have a legal obligation to retain it, and we may terminate the child’s account if applicable.
12. OTHER PROVISIONS
Third-Party Services: Certain features of the Services may link to or allow you to interface, interact, or share information with third-party websites, services, products, and technology (collectively, “Third-Party Services”). Any information disclosed to or collected by a Third-Party Service is subject to that Third-Party Service’s privacy policy. We do not control Third-Party Services and are not responsible for compatibility issues, errors, or bugs caused by Third-Party Services or their updates. We encourage you to read the privacy policies of each Third-Party Service you interact with. Your interactions with Third-Party Services are at your own risk.
Supervisory Authority: If your personal data is subject to the data protection laws of the EEA, Switzerland, or the UK, you have the right to lodge a complaint with your competent supervisory authority if you believe our processing violates applicable law.
13. CONTACT US
Swappie is the controller of personal data processed under this Privacy Policy. If you have questions about this Privacy Policy or wish to exercise your rights, contact us.