Privacy policy
Effective October 16, 2026. Rasel Hakkani, trading as Swift Web Dev, Kodomtoli, New Bridge Rd, Gaibandha - 5700, Bangladesh.
This policy explains how Rasel Hakkani, trading as Swift Web Dev ("we") handles personal data in two roles: as a controller for our own customers and website visitors, and as a processor for the lead data our customers upload. For lead data, the customer is the controller and our Data processing addendum applies.
1. Data we collect as controller
| What | Why | Legal basis |
|---|---|---|
| Account data: name, email, password hash, organisation, role | Create and secure your account | Contract |
| Billing data: plan, invoices, billing email, country; card details are held by our payment processor, not us | Charge for the Service, keep tax records | Contract, legal obligation |
| Usage and log data: IP address, device, actions in the app, error logs | Security, abuse prevention, support, improving the Service | Legitimate interests |
| Support and contact messages | Answer you | Legitimate interests, contract |
| Website cookies | See the cookie policy | Legitimate interests (essential), consent (optional) |
2. Data we process for customers
Leads and their details, website content fetched for research, emails written and sent, replies received, tracking events and unsubscribe records. We process this only on the customer's instructions to provide the Service.
3. Recipients and sub-processors
We share data only with service providers that help us run the Service, under contracts that protect it. Our current sub-processors are: OVHcloud (server hosting and backups), Paddle (payments, as merchant of record), Maileroo (account emails such as verification and password reset), and, for Swift Pilot only, Xkiro (AI provider for Swift Pilot; passes requests to models from companies such as Alibaba, Anthropic and Google). Only if you connect your own AI key, requests go instead to the provider you chose (for example OpenAI, Anthropic or Google), and when you connect your own mailboxes, data goes to those providers, in each case under your own agreements with them. We update this list before adding a new sub-processor.
Swift Pilot (our built-in AI)
Swift Pilot is the AI writing assistant included with paid plans. It is an AI service we provide through a third-party API service: requests are sent to Xkiro, our AI provider, which passes each request to an available AI model from companies such as Alibaba, Anthropic and Google. The model used can differ from one request to the next and you do not choose it.
What is sent: when a campaign uses Swift Pilot, we send your writing instructions, the lead's details from your list, and the text of the website pages the campaign reads for that lead, so the email can be written. Nothing else from your account is sent.
Usage: Swift Pilot is charged by usage against a Swift Pilot credit balance: paid plans include a monthly credit, and you can top up any time.
Your own AI key: if you connect your own AI key instead, requests go to the provider you chose (for example OpenAI, Anthropic or Google) under your own account with that provider, with no Swift Pilot credit used, and Swift Pilot is not used.
4. International transfers
Where data leaves the UK or EEA, we rely on adequacy decisions or Standard Contractual Clauses with appropriate safeguards.
5. Retention
- Account and Customer Data: for the life of the account, then 30 days after cancellation, then deleted.
- Billing records: for as long as tax and accounting law requires.
- Activity logs: 30 days by default; a workspace admin can change the period.
- Security audit records (sign-ins and account changes): for the life of the account, deleted with it.
- Unsubscribe and suppression records: kept as long as needed to keep honouring the opt-out.
6. Security
Data is encrypted in transit. Mailbox passwords and API keys are encrypted at rest with per-workspace keys and are never shown again after saving or written to logs. Access is limited to staff who need it.
7. Your rights
Depending on where you live you may have the right to access, correct, delete, restrict or object to processing of your data, to data portability, and to withdraw consent. Account holders can export their data from the app. Email privacy@swiftoutbox.com for any request. You can also complain to your data protection authority.
If you received an email sent with Swift Outbox: the sender is our customer and controls your data. Use the unsubscribe link in the email, or contact the sender. If you cannot reach them, write to privacy@swiftoutbox.com and we will pass on your request and help where we can.
8. Children
The Service is for businesses and is not directed at children under 16.
9. Changes
We will post updates here and email account holders about material changes.
10. Contact
Rasel Hakkani, trading as Swift Web Dev, Kodomtoli, New Bridge Rd, Gaibandha - 5700, Bangladesh. Privacy contact: privacy@swiftoutbox.com.