1. Who We Are
Controller: Swayton DOO
Registration number: 21866997
Tax number: 113439722
D-U-N-S: 680887258
Registered address: Djure Jaksica 1, 11000 Beograd, Serbia
Website: https://scalemint.biz
Email: alex@scalemint.biz
This Privacy Policy explains how we collect, use, share, and protect personal data when you visit our website, contact us, or work with us as a client, partner, or supplier.
2. Scope of This Policy
This Policy applies to personal data we process in connection with:
- Visitors to our website;
- Existing and prospective clients and partners;
- Recipients of our marketing communications;
- Individuals whose data we process in the context of running online advertising campaigns on behalf of clients, where applicable.
Depending on the specific campaign setup, we may act as a data controller (for our own marketing) or as a data processor (when acting strictly on written instructions from our clients).
3. Categories of Data We Collect
3.1 Data You Provide to Us
- Contact details (name, business email address, phone number, company name);
- Information you provide in contact forms or via email;
- Billing information (for clients and suppliers, as necessary for invoicing);
- Any other information you voluntarily submit (e.g. project briefs, feedback).
3.2 Data We Collect Automatically
When you visit our website, we may automatically collect:
- IP address and approximate location;
- Device type, browser type, operating system;
- Pages visited, time spent on pages, clickstream data;
- Referring URLs and campaign parameters (e.g. UTM tags, click IDs).
3.3 Data from Cookies and Similar Technologies
We use cookies and similar technologies for essential website functions, analytics, and marketing. For more details, please see our Cookie Policy.
4. How We Use Personal Data
We use personal data for the following purposes:
- To provide, maintain and improve our website and services;
- To respond to your inquiries and communicate with you;
- To prepare and manage proposals, contracts and invoices;
- To analyze performance of our marketing campaigns and website;
- To run remarketing or retargeting campaigns, where legally permitted;
- To comply with legal obligations and enforce our rights.
5. Legal Bases for Processing (GDPR / UK GDPR)
Where the GDPR or UK GDPR applies, we process personal data on the following legal bases:
- Contract performance: to enter into and perform contracts with clients and partners;
- Legitimate interests: to operate, secure and optimize our services and marketing activities, balanced against your rights and freedoms;
- Consent: for certain types of cookies, analytics, or marketing where local law requires consent;
- Legal obligations: to comply with tax, accounting and other regulatory requirements.
6. Use of Google Products and Third-Party Tools
We may use third-party tools, including but not limited to:
- Google Ads (including remarketing and conversion tracking);
- Google Analytics or similar analytics platforms;
- Tag management systems (e.g. Google Tag Manager);
- Other advertising platforms or tracking tools (e.g. Meta advertising, affiliate and tracking platforms).
These tools may use cookies or similar technologies to collect information about your visits to our website and other sites over time, in order to measure performance and, where permitted, to deliver personalized ads.
Where required by applicable law (including Google’s EU User Consent Policy), we obtain your consent before setting cookies or using personal data for personalized advertising in the European Economic Area, the UK and Switzerland.
7. Sharing of Personal Data
We do not sell personal data. We may share personal data with:
- Service providers (e.g. hosting, analytics, CRM, accounting) under appropriate data protection agreements;
- Clients, where we act as a processor and the data relates to campaigns we manage on their behalf;
- Professional advisors (e.g. legal, tax, financial) bound by confidentiality;
- Public authorities where required by law or to protect our rights, property or safety.
8. International Transfers
Our company is based in Serbia, and some of our service providers may be located in the European Union, the United Kingdom, the United States or other countries. Where required, we use appropriate safeguards such as standard contractual clauses or equivalent mechanisms to protect personal data transferred outside your jurisdiction.
9. Data Retention
We retain personal data only for as long as necessary for the purposes described in this Policy, including:
- For the duration of our business relationship and for a reasonable period afterwards;
- For as long as required by tax, accounting, and other legal obligations;
- For shorter periods where you withdraw consent and no other legal basis applies.
When data is no longer needed, we will delete or anonymize it in a secure manner.
10. Your Rights
Depending on your jurisdiction, you may have some or all of the following rights:
- Right of access to your personal data;
- Right to rectification of inaccurate or incomplete data;
- Right to erasure (“right to be forgotten”) in certain circumstances;
- Right to restriction of processing;
- Right to data portability;
- Right to object to certain processing, including direct marketing;
- Right to withdraw consent at any time, where processing is based on consent.
To exercise these rights, please contact us at privacy@YOUR_DOMAIN_HERE. We may need to verify your identity before responding to your request.
11. California and Other Regional Rights
If you are a resident of California or other jurisdictions with specific privacy laws, you may have additional rights, including the right to know what categories of personal data we collect, the sources of that data, the purposes of use, and the right to request deletion or restriction in certain cases.
We do not sell personal information as “sale” is defined under California law.
12. Security
We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration. However, no system can be completely secure, and we cannot guarantee absolute security of information transmitted over the internet.
13. Third-Party Websites
Our website may contain links to third-party websites or services. We are not responsible for the privacy practices of such third parties. We encourage you to review the privacy policies of those websites before providing any personal data.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated version will be indicated by a new “Effective date” at the top of this page.
15. Contact Us
If you have any questions or concerns about this Privacy Policy or our data practices, please contact:
Swayton DOO
Djure Jaksica 1, 11000 Beograd, Serbia
Email: privacy@YOUR_DOMAIN_HERE