Privacy Policy

This Privacy Policy (“Policy”) sets out how BullSwipe Limited, a company incorporated in Hong Kong with its registered office at Unit 01, 13/F, The Gold & Silver Commercial Building, 12–18 Mercer Street, Sheung Wan, Hong Kong (“BullSwipe”, “Company”, “we”, “us” or “our”), collects, uses, discloses, and protects your personal data when you access or use our services, applications, and websites (the “Services”).

By using our Services, you agree to the practices described in this Policy. If you do not agree, you must not use our Services.

We may amend this Policy at any time by posting the updated version on our website or mobile application, or by notifying you directly. Your continued use of the Services after such updates constitutes your acceptance of the revised Policy.

For privacy-related inquiries, please contact us at: dpo@bullswipe.com

We may collect the following categories of personal data from you and, where applicable, from related persons such as beneficial owners, directors, or authorised signatories (“Relevant Persons”):

• Account Information: Contact details, account identifiers and information used to administer your account.
• Identity Verification (KYC): Full legal name, date of birth, passport or ID details, nationality, country of origin, country of residence, address, phone number, occupation and, where applicable, beneficial ownership details. Country of origin and country of residence are captured separately. Proof of address may be requested where required.
• Transaction Data: Wallet balances, deposit and withdrawal history, transfers, and payment records.
• Technical Data: IP address, device identifiers, operating system, browser type and usage logs.
• Marketing Preferences: Language, campaign interaction and consent or opt-out preferences, where applicable.
• Other Information: Information you voluntarily provide, such as feedback, surveys or communications with support.

• Directly from You: During sign-up, identity verification, use of the Services or communications with BullSwipe.
• Automatically: Technical and usage information associated with access to the Services, where applicable. See Cookies and Local Storage below.
• Third Parties: Information from service providers, compliance partners or public sources where relevant to providing the Service and permitted by applicable law.

We use your personal data for purposes including:

1. To operate, manage, and secure your account.
2. To perform KYC/AML checks and comply with regulatory requirements.
3. To process transactions, provide statements, invoices, and receipts.
4. To prevent, detect, and investigate fraud or suspicious activity.
5. To improve, personalise, and optimise our Services.
6. To send operational and service-related communications (mandatory).
7. To send marketing communications to which you have opted in.
8. To comply with laws, regulations, and court orders.
9. To enforce our Terms & Conditions and protect the rights of BullSwipe, our users, and partners.

We do not sell your personal data. Where relevant to the purposes described in this Policy and permitted by applicable law, we may share your data with:

• Service Providers: Providers supporting the operation of the Services, including account access, identity checks, compliance, hosting, communications and transaction functionality.
• Affiliates: Relevant BullSwipe group entities.
• Professional Advisers: Auditors, legal counsel or compliance consultants.
• Regulators & Law Enforcement: Where required by applicable law.
• Business Transfers: In connection with mergers, acquisitions or restructuring.
• Authorised Parties: Persons you instruct us to share your data with.

The role and obligations of a recipient depend on the relevant service, arrangement and applicable law.

Your personal data may be processed in a jurisdiction other than the one where you live. The requirements that apply to a transfer depend on the jurisdictions involved, the purpose of the processing and applicable data protection law. BullSwipe handles such transfers subject to those applicable requirements.

Personal data is retained for the period required by the relevant purpose, contractual obligations and applicable legal and compliance requirements. This may include retaining information to comply with record-keeping obligations, resolve disputes and enforce agreements. The applicable period depends on the data and the circumstances.

Where required by applicable law, BullSwipe will not use personal data for direct marketing without the required consent or indication of no objection. A person may withdraw consent or require BullSwipe to stop using their personal data for direct marketing at any time without charge through the unsubscribe or request channel provided by BullSwipe.

Operational notices, such as changes to Terms or account-security communications, are separate from direct marketing.

The BullSwipe website uses browser local storage to remember your motion preference. Local storage keeps that preference in your browser. You can change it using the website’s motion control or clear it through your browser settings.

Technical information associated with accessing the website may be processed to deliver and operate it. The mobile application and any external services may use technologies relevant to their own functionality. This website’s motion preference does not describe those separate services.

We take measures intended to protect personal data, taking account of the nature of the information and applicable requirements. No system or method of transmission can be guaranteed to be completely secure. Keep your account credentials confidential and contact support@bullswipe.com if you suspect unauthorised account access.

BullSwipe does not knowingly provide Services to individuals under 18 years old. Parents or guardians may contact us if they believe their child has provided personal data. Information brought to our attention will be handled in accordance with applicable legal and compliance requirements.

Your rights depend on the law that applies to your circumstances and are subject to its requirements and exceptions.

• Hong Kong: Where the Personal Data (Privacy) Ordinance applies, a data subject may request access to and correction of personal data held about them, subject to the requirements and exceptions of applicable law. A data subject may also require BullSwipe to cease using their personal data for direct marketing as provided by law.
• EU/EEA: Where the GDPR applies, relevant rights may include access, rectification, erasure, restriction, objection, data portability and withdrawal of consent, subject to the applicable conditions and exceptions.
• United States: Where applicable state privacy law provides such rights, these may include knowing about, accessing, correcting or deleting personal data, opting out of specified uses and protection against unlawful discrimination for exercising rights.

Requests may be sent to dpo@bullswipe.com. Identity verification may be required.

Our Services may contain links to third-party websites or integrations. We are not responsible for their content, privacy practices, or security. Please review their policies separately.

We may update this Policy periodically. Significant changes will be communicated via email or app notifications. Continued use of our Services after changes indicates acceptance.

If you have questions, concerns, or requests regarding this Policy or your personal data:

• dpo@bullswipe.com
• BullSwipe Limited
  Unit 01, 13/F, The Gold & Silver Commercial Building, 12–18 Mercer Street, Sheung Wan, Hong Kong

Last Updated: 1 September 2026