Privacy Policy

1. Who We Are

This Privacy Policy explains how The Swing Desk ("we," "us," "our") collects, uses, and protects information in connection with theswingdesk.com and the private Telegram community sold through it. It should be read together with our Terms of Service.

2. Information We Collect

We collect the following categories of information:

• Checkout information. When you purchase, Stripe processes your payment and may collect your email address and billing details. We do not receive or store your full card number — Stripe handles that directly.
• Telegram identifiers. When you interact with our bot or request to join the private channel, we receive your Telegram user ID, username, and the content of messages you send to the bot (for example, support requests).
• Consent record. When you check the Terms-of-Service box on our Pricing page, we record the timestamp, the IP address the request came from, and the version of the Terms then in effect, as proof of your consent.
• Ad click identifiers. If you arrive from an ad campaign, we may read click identifiers present in the page URL (such as fbclid, gclid, gbraid, or wbraid) and, if you go on to purchase, associate them with your purchase record for advertising-attribution purposes.
• Support messages. Messages you send our bot outside the purchase flow are forwarded to our team so we can reply, and the exchange is retained for support history.

3. How We Use Your Information

• To provision, maintain, and manage your access to the private channel.
• To verify your consent to our Terms and Refund Policy.
• To communicate with you about your access, renewals, and support requests.
• To detect and prevent fraud, abuse, and payment disputes.
• To comply with legal and tax obligations.
• Where we have configured advertising accounts, to measure the effectiveness of ad campaigns by sending hashed conversion data to platforms such as Meta and Google — this is off by default and only activates once we've configured it for this brand specifically.

4. Legal Bases for Processing (GDPR)

If you are located in the EEA, UK, or another jurisdiction with similar requirements, we rely on the following legal bases: performance of a contract with you (providing the access you purchased); our legitimate interests in preventing fraud, securing the Service, and maintaining accurate business records, balanced against your rights; and your consent, for example when you agree to our Terms on the Pricing page or where advertising-attribution processing requires it. You may withdraw consent at any time where consent is the basis for a particular use, without affecting the lawfulness of processing carried out before withdrawal.

5. Who We Share Information With

We use a small number of service providers to operate the Service:

• Stripe — payment processing.
• Telegram — bot messaging and private-channel access (see Section 6 below).
• Cloudflare — website hosting, application infrastructure, and database storage.
• Meta and Google advertising platforms — only if and when we configure ad accounts for this brand, and only using hashed identifiers for conversion measurement, never raw contact details.

We do not sell your personal information, and we do not share it with third parties for their own independent marketing purposes.

6. Telegram's Role

The private channel and our support bot run on Telegram's platform. Telegram is a separate, independent service with its own privacy policy and terms, which govern how Telegram itself handles data within its platform — we do not control Telegram's internal data practices, and we encourage you to review Telegram's own privacy policy directly. Whether Telegram acts as an independent controller of that data or as a processor on our behalf is a question that depends on facts and legal interpretation we are not in a position to determine unilaterally, and we don't declare a specific classification here. What we can tell you plainly is what we ourselves collect and store, as described in Section 2.

7. Data Retention

We keep purchase, access, and consent records for as long as needed to administer the Service, maintain accurate support and audit history, meet legal and tax obligations, and defend against payment disputes — we do not route purchase or access records through automatic time-based deletion, since doing so would undermine our ability to prove consent and access history if a dispute arises later. This does not affect your right to request erasure under Section 8, which we honor on request subject to the exceptions described there.

8. Your Rights

If GDPR or a similar law applies to you, you have the right to: request access to the personal data we hold about you; request correction of inaccurate data; request erasure of your data; request that we restrict or object to certain processing; request a portable copy of data you provided to us; and withdraw consent at any time where processing is based on consent. To exercise any of these rights, contact us at [email protected]. Some requests may be limited where we have an overriding legal or legitimate interest in retaining certain records, such as payment and consent evidence needed to resolve a dispute. You also have the right to lodge a complaint with your local data protection supervisory authority.

9. International Data Transfers

Our service providers — including Stripe, Telegram, and Cloudflare — operate infrastructure in multiple countries, which may include locations outside your own country or the EEA/UK. Where this involves a transfer of your data, we rely on the safeguards those providers themselves implement (such as standard contractual clauses) to protect it.

10. Cookies and Tracking

This website does not set tracking cookies. It does read advertising click identifiers (such as fbclid or gclid) from the page URL when present, as described in Section 2, and stores them against your purchase record only if you go on to buy.

11. Children's Privacy

The Service is not directed at, and is not intended for use by, anyone under 18. We do not knowingly collect information from minors.

12. Security

We use reasonable technical and organizational measures to protect the information we hold, including relying on Stripe for payment data and Cloudflare's infrastructure for storage. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of the Service after an update constitutes acceptance of the revised policy.

14. Contact Us

For any privacy question or to exercise a right described above, contact us at [email protected] or via our Contact page.