Privacy Policy

About this policy

This policy covers the BySwap public website (byswap.io) and the BySwap web application, where you can sign in, get a Solana wallet and use BySwap's market tools. BySwap is in development: trading and withdrawals are built but not yet available to users. Where this policy describes trades and withdrawals, it explains how they handle information when they are available.

The public website runs no scripts, and BySwap sets no cookies on it. Like every website, it receives your IP address and browser information with each request; it is delivered by Cloudflare, which processes that information to serve the pages and can set its own security cookies.

Who is responsible

BySwap is a brand name, not a registered company. It is operated by an individual, who is responsible for the information described here.

Questions and requests about your information: [email protected].

Information BySwap collects

BySwap collects only what it needs to sign you in, give you a wallet, carry out what you ask it to do, answer your messages and keep the service secure:

• Google sign-in: the identity token Google issues when you choose to sign in with Google (see "Google user data" below).
• Phantom sign-in: your Phantom wallet's public address and the sign-in messages you approve in Phantom. Phantom never shares your wallet's private key with BySwap.
• Your BySwap wallet: its public Solana address, created for your account by the wallet provider Turnkey.
• Transactions you request: for trades, the token, amounts, fee and the resulting transaction signature; for withdrawals, the source wallet, destination address, asset and amount.
• Technical information: your IP address and browser information (such as the user agent) reach BySwap's servers and its network provider Cloudflare with every request. BySwap's web server access logs can record your IP address, user agent and other request headers, with each request's method, path, status and timing; they never record cookies or authorization headers, and they drop the query part of the requested address (the Referer header, also logged, can contain the address of the BySwap page you came from). Rate limits keep only a one-way hash of your IP address, for up to an hour.
• Messages to support: when you email BySwap, your email address, the contents of your message and anything you attach.

BySwap's website and application contain no analytics, advertising or tracking code, BySwap does not ask for your seed phrase or private key, and it does not check your identity documents.

Google user data

Access: when you sign in with Google, BySwap asks Google only for the basic sign-in scopes openid, email and profile. BySwap does not request access to Gmail, Google Drive, Google Calendar, Contacts or any other Google data, and it never receives your Google password.

What BySwap uses: from the identity token Google returns, BySwap uses your Google account identifier (with Google's issuer), your email address, which Google must report as verified, and, during the withdrawal security check, the time of your last Google sign-in (auth_time) and the sign-in methods Google reports (amr). The token can also contain your name and profile picture because of the profile scope; BySwap itself does not use them, but they remain in the token BySwap passes to Turnkey.

• To identify your BySwap account: your Google account identifier is what links your Google sign-in to your BySwap account and wallet.
• To create and sign in to your wallet account: BySwap sends the identity token, and your email address, to Turnkey, which secures your wallet and keeps your email address with your wallet account. Turnkey verifies the token itself.
• To show which account you are signed in with: the app displays your email address as your account's display name (account menu and account page).
• To protect withdrawals: before a withdrawal from a Google-secured account, BySwap asks you to sign in with Google again, suggests your email address to Google for that sign-in, and checks that the sign-in is recent before approving.

Storage: BySwap's own databases do not store your email address or your Google identity token; your email address is kept by Turnkey with your wallet account. BySwap stores a one-way hash of your Google account identifier in its permanent account records, keeps your Google account identifier with your sign-in session until the session expires (8 hours after sign-in, even if you log out earlier), and keeps one-way hashes of used identity tokens so that a token cannot be used twice: sign-in tokens' hashes until the token expires, and the hashes of the tokens from withdrawal security checks permanently, in BySwap's withdrawal security records.

Sharing: BySwap shares Google user data only with Turnkey, for the purposes above (Cloudflare, BySwap's network provider, carries it in transit). BySwap does not sell Google user data, does not use or transfer it for advertising, and does not use it for any purpose other than providing and securing your BySwap account.

BySwap's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

You can remove BySwap's access to your Google account at any time at https://myaccount.google.com/permissions. Your BySwap account remains linked to your Google account identifier.

Phantom sign-in and Turnkey wallet services

Phantom: when you sign in with Phantom, you approve a sign-in message in Phantom, and BySwap checks that it was signed by your Phantom wallet. Your Phantom public address identifies your BySwap account and is kept in BySwap's permanent account records. A withdrawal from a Phantom-secured account needs your approval in Phantom of a statement that names the recipient, amount, asset and expiry; BySwap keeps that approval while the withdrawal is pending, and approvals that BySwap co-signs are kept permanently in its withdrawal security records.

Turnkey: each BySwap account has its own Turnkey account holding one Solana wallet. Turnkey keeps your sign-in method (your Google account identity or your Phantom public key), your email address for Google accounts, the public keys of your sign-in sessions, and the security rules that decide which transactions your wallet may sign. Turnkey holds your wallet's keys and processes this information under its own terms and privacy policy.

Wallet and blockchain data

Your wallet address, balances and every transaction your wallet makes are recorded on the Solana blockchain, which is public and permanent: anyone can see them, and neither BySwap nor anyone else can change or delete them. BySwap reads balances, token holdings and transaction history for your wallet address through Solana network providers to show them to you.

Security monitoring and audit records

To protect accounts and funds, BySwap keeps:

• Security records in its database that by design cannot be deleted: new entries are only added, a record's status only moves forward, and a closed record cannot change. They hold the link between each account, its sign-in identity and its wallet; each trade and withdrawal with its status history; and each withdrawal approval that BySwap co-signs, including the one-way hashes of the identity tokens used for withdrawal security checks.
• Server and security logs, including logs of withdrawal approvals, which record a pseudonymous account tag, part of the request identifier, the wallet addresses, asset and amount.
• Security counters (for example, failed or unauthorized signing attempts and uncertain transactions), which count events by type only, without any account, address, amount or other personal information, so that problems can be detected.

Why BySwap uses information, and legal bases

BySwap uses personal information only for these purposes. Where a law such as the GDPR requires a legal basis, the basis is given for each:

• To provide the service you asked for: signing you in, keeping you signed in, creating your wallet, showing your balances and history, and carrying out the trades and withdrawals you request. Basis: performing the agreement with you (the Terms of Service).
• To protect accounts, funds and the service: rate limits, replay protection, withdrawal security checks, security records, logs and monitoring. Basis: legitimate interests in keeping users' funds and the service secure and preventing fraud and abuse.
• To answer your messages and requests. Basis: performing the agreement with you, and legitimate interests in supporting users.
• To meet legal obligations, respond to lawful requests from authorities, and establish or defend legal claims. Basis: legal obligation, or legitimate interests in protecting legal rights.

BySwap does not use personal information for advertising or marketing, does not build marketing profiles, and does not make decisions about you based solely on automated processing that have legal or similarly significant effects. The security checks that can stop a withdrawal check whether a request is genuine (for example, whether the sign-in is recent); they are not an assessment of you.

Who receives information

• Turnkey (wallet infrastructure): your Google identity token (with everything Google put in it, including your name and profile picture) and email address, or your Phantom public key; and every signing and withdrawal request for your wallet. Turnkey holds your wallet's keys.
• Google (sign-in): your browser connects to Google directly when you sign in with Google, so Google receives your IP address and learns that you are signing in to BySwap; for a withdrawal security check BySwap suggests your email address to Google.
• Phantom: sign-in and approval requests reach the Phantom browser extension, or on phones the Phantom app through Phantom's links (phantom.com), carrying BySwap's address and the messages you are asked to approve.
• Solana network providers (Helius and other RPC providers): your public wallet address and transactions, sent by BySwap's servers to read balances and history and to submit transactions. Transactions on the Solana blockchain are public.
• Jupiter (trade routing): when BySwap quotes or prepares a trade through Jupiter, your wallet address and the trade's token, amount and slippage.
• Cloudflare (network and security): every request to byswap.io and to BySwap's web application passes through Cloudflare.
• Google Cloud Key Management Service: only a cryptographic digest of a withdrawal approval that BySwap's security service signs; no personal information.
• Namecheap (email hosting): messages you send to BySwap's support address are kept in BySwap's mailbox at Namecheap Private Email.
• Hosting: BySwap's servers and databases run on cloud servers rented from a hosting provider, which stores the data they hold.
• Authorities and others when the law requires it: BySwap may disclose information where required by applicable law, such as a valid court order.

BySwap does not sell personal information and does not share it with advertisers or data brokers.

International transfers

BySwap is available internationally, and the providers listed above operate in several countries. Your information may therefore be processed in countries other than the one where you live, including the United States, whose data protection laws may differ from yours. BySwap uses these providers under their published terms for the services described above.

Cookies and browser storage

The public website sets no cookies. In the web application, BySwap itself sets only these cookies, all set by BySwap's server and unreadable by page scripts (Cloudflare can set its own security cookies):

• byswap-session: keeps you signed in; it ends with your session (at most 8 hours) or when you log out.
• byswap-google-flow: ties a Google sign-in to the browser that started it; at most 10 minutes, removed after use.
• byswap_chain: remembers the blockchain you chose in Discover; up to 1 year.

Your browser also keeps, for BySwap only, in local storage: your watchlist, recent searches, theme, layout and display preferences, and your trading preferences (such as slippage, which is sent with your trade requests); and short-lived sign-in and account-setup progress (session storage, cleared when the tab closes); the progress of a Phantom sign-in on a phone (removed when it ends, and unusable after 10 minutes); and security keys for your session that cannot be exported from your browser. BySwap uses cookies and browser storage only for sign-in, security and the features you use, never for advertising or tracking.

How long information is kept, and deletion

• Sign-in state: up to 10 minutes. Sessions: up to 8 hours.
• Completed trade records: 30 days in BySwap's operational store.
• Security and transaction records are append-only records that BySwap keeps without a set end date: account-to-wallet links with the sign-in identity (a one-way hash of your Google account identifier, or your Phantom public key), trades, withdrawals (including destination and amount) and their approvals.
• Server logs, including security logs of withdrawal approvals, and support emails: BySwap has not yet set fixed periods. They are kept for security, troubleshooting and support, and this policy will state the periods once they are set.
• Information held by Turnkey, Cloudflare and the other providers above: according to their own policies.

BySwap does not yet offer self-service account deletion or data export. You can ask for your information to be deleted by writing to [email protected]. Some information cannot be deleted: transactions on the Solana blockchain are permanent, and BySwap's security records are designed so that they cannot be deleted, because they protect the integrity of accounts and funds.

Your privacy rights

Depending on the laws that apply where you live, you may have the right to ask for access to your personal information, to have it corrected or deleted, to restrict or object to its use, and to receive it in a portable format, and the right to complain to a data protection authority. To use these rights, write to [email protected]. BySwap may need to confirm that a request comes from the account holder, for example by asking you to sign in, before acting on it.

Age

There is no minimum age for browsing the public website, which collects only the technical request information described above. Signing in, holding a BySwap wallet and trading are only for people who may lawfully do so where they live, including any minimum age that applies there (see the Terms of Service). BySwap does not verify age.

How BySwap protects information

• Your wallet's keys are held by Turnkey, not by BySwap. BySwap never asks for your seed phrase or private key.
• Each withdrawal needs your own separate confirmation (a fresh Google sign-in, or an approval in Phantom). BySwap's own approvals of withdrawals are signed with keys kept in Google Cloud Key Management Service.
• Trades are signed with short-lived session keys created in your browser that cannot be exported, and BySwap's server checks each trade independently before co-signing it.
• Connections are encrypted (HTTPS), sign-in cookies cannot be read by page scripts, and rate limits and security records help detect and stop abuse.

No system is perfectly secure. Security concerns: [email protected].

Changes to this policy

When this policy changes, the new version is published at this address with a new effective date.

Contact

For any question about this policy or your information: [email protected].