PRIVACY POLICY

Effective Date: July 2, 2026

This Privacy Policy (the “Policy”) explains how GENART SYSTEMS LTD – the data controller (“SWAGTOONS,” “we,” “us,” or “our”) – collects, uses, discloses, and protects information when you use the Swagtoons website, mobile application, and related services that link to this Policy (collectively, the “Service”).

This Policy is incorporated into our Terms of Service. If a term is not defined here, it has the meaning given in the Terms of Service.

1. Scope

This Policy applies to information we collect through the Service and related communications (such as support emails and in-app notices). It does not apply to third-party websites, services, content licensors, advertising networks, application stores, or other applications that may be linked from or integrated with the Service – those are governed by their own privacy practices.

2. Age Requirement

The Service is intended for users 16 years of age or older. We do not knowingly collect personal information from children under 16. If you believe a child under 16 has provided personal information to us, contact support@swagtoons.net, and we will take appropriate steps to delete it.

3. Information We Collect

We may collect the following categories of information.

Information you provide

· Account information: email address, login credentials (stored in hashed form where applicable), display name (if provided), preferred language, and basic account settings.

· Profile and viewing preferences: content preferences, language selections, favorites, watchlists, ratings, reactions, and similar information you choose to provide.

· User Inputs: ratings, reviews, comments, and other materials you submit (where such features are available).

· Purchase information: subscription plan, billing country, transaction history, and other purchase-related details provided at checkout.

· Support communications: messages you send to support and any information you include in those communications.

Information collected automatically

· Viewing and usage data: titles, episodes, and trailers you view, playback events (start, pause, resume, completion), watch duration, search queries, recommendations interacted with, navigation paths, clicks, timestamps, and other activity within the Service.

· Device and technical data: IP address, device type and model, operating system and version, app version, browser type, screen resolution, language and locale, time zone, network type, mobile carrier, crash logs, performance diagnostics, and similar technical information.

· Mobile identifiers: where you use our mobile application, we may process device advertising identifiers (such as Apple IDFA or Google Advertising ID) and other app-instance identifiers, subject to applicable platform permissions and your device settings.

· Approximate location: approximate location derived from your IP address (typically at the country, region, or city level), used in particular for content availability, regional pricing, fraud prevention, and analytics. We do not collect precise GPS location.

· Push notification tokens: if you enable push notifications, we receive a device token from the relevant push service to send you notifications.

· Cookies and similar technologies: we may use cookies, pixels, mobile SDKs, software development kits, and local storage to operate the Service, remember preferences, enhance security, measure performance, and support marketing where permitted. See our Cookie Policy for additional details.

Payment information

Purchases are processed by third-party payment processors. We generally receive limited payment-related information such as payment status, transaction identifiers, billing country, and the last four digits of a card (if provided by the processor). We do not store full payment card numbers.

If you purchase through an application store (Apple App Store or Google Play), that store processes your payment and provides us with limited information needed to provision and manage your subscription.

Information from third parties

We may receive information about you from:

· application stores (e.g., subscription status, in-app purchase events);

· payment processors (transaction status and identifiers);

· attribution and analytics providers (campaign and acquisition information, subject to your device permissions);

· advertising and marketing partners (for measurement and reporting, subject to consent where required);

· content licensors and rights holders (for example, where required for audience reporting required by licensing terms).

Inferences and derived data

We may generate signals, segments, recommendations, and audience clusters based on your use of the Service (for example, what you watch and rate). These are used to provide, personalize, and improve the Service.

Sensitive information

We do not intentionally collect sensitive personal information (such as government IDs, full payment card numbers, precise geolocation, or health/medical records). Please do not submit sensitive personal information through the Service.

We collect and use personal information for the business and commercial purposes described below and retain it as described in the Data Retention section.

4. How We Use Information

We use information for the following purposes:

· Provide and operate the Service – create and maintain accounts, deliver Content (including streaming, downloads where available, and recommendations), maintain core functionality, and enable Service features;

· Personalization and improvements – tailor recommendations, watchlists, language and dub options, and improve features, quality, and performance;

· Content licensing and availability – enforce regional availability of specific titles, apply parental or age restrictions, and generate audience reports for licensors as required by content agreements (using aggregated or de-identified data where possible);

· Security and fraud prevention – protect accounts, prevent abuse, detect suspicious activity (including chargeback fraud, account sharing beyond what is permitted, and credential abuse), and enforce our Terms;

· Payments and billing – process transactions, manage subscriptions and trials, send receipts, and handle billing issues;

· Customer support – respond to requests and resolve technical issues;

· Analytics – understand how users interact with the Service and improve usability and performance;

· Marketing and communications – send service updates and, where permitted, marketing messages, push notifications, and personalized promotions; you may opt out of marketing communications as described below;

· Legal and compliance – comply with applicable laws, lawful requests, content licensing obligations, and protect our rights and users;

· Accounting, audits, and recordkeeping – maintain financial records, reconcile transactions, support audits, comply with tax and accounting obligations, and respond to lawful requests from regulators or authorities.

5. Legal Bases (EEA/UK)

As a controller established in the EU, we process personal data under the GDPR (and the UK GDPR where applicable) on the following legal bases:

· Contract (Art. 6(1)(b)) – to provide the Service, create and manage accounts, deliver Content, enable Paid Features, and provide customer support related to the Service;

· Legitimate interests (Art. 6(1)(f)) – to secure the Service, prevent fraud and abuse, maintain and improve the Service, enforce content licensing terms, develop and refine recommendations, and protect our rights and users;

· Consent (Art. 6(1)(a)) – where required, for non-essential cookies and similar technologies (including analytics and marketing cookies and SDKs), for processing of mobile advertising identifiers, and for certain marketing communications. You can withdraw consent at any time;

· Legal obligation (Art. 6(1)(c)) – to comply with applicable laws (including accounting, tax, and regulatory requirements) and respond to lawful requests.

6. How We Disclose Information

We may disclose information in the following circumstances:

· Service providers. We may share information with vendors and service providers that help us operate the Service (for example, cloud hosting and CDN providers, content delivery networks, analytics and product-analytics providers, customer support and ticketing tools, email and push notification delivery, attribution and crash-reporting providers, fraud and risk-scoring providers, and payment processors). They are authorized to process information only as needed to provide services to us and are subject to contractual obligations where appropriate;

· Application stores and platforms. Where relevant, we share information with Apple, Google, and other application stores or platforms to provision subscriptions, validate in-app purchases, and manage entitlements;

· Content licensors. Where required by content licensing arrangements, we may share aggregated or de-identified viewing data and audience reports with content licensors and rights holders. Personally identifying information is not shared for this purpose unless required by law or explicitly required by the licensing arrangement;

· Advertising and analytics partners. Where permitted (and subject to consent where required), we may share certain information with advertising, attribution, measurement, and analytics partners to operate, measure, and improve marketing and to provide more relevant content;

· Legal, safety, and enforcement. We may disclose information if we believe disclosure is necessary to comply with law, respond to lawful requests, protect the rights and safety of SWAGTOONS, our users, or others, or enforce our Terms and Policies;

· Business transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information may be disclosed or transferred as part of that transaction, subject to customary confidentiality protections;

· With your direction. We may share information with third parties when you request or direct us to do so.

We may also disclose aggregated or de-identified information that cannot reasonably be used to identify you.

7. Cookies and Similar Technologies

We use cookies, mobile SDKs, pixels, local storage, and similar technologies to operate the Service, enhance security, and, where permitted, support analytics, personalization, and marketing.

Where required by applicable law, non-essential cookies and similar technologies (including analytics and marketing cookies and SDKs) will be used only after you provide consent. You can manage your cookie choices through our cookie banner and preference tools (where available), through your browser settings, or through your device's mobile advertising controls (for example, “Limit Ad Tracking” / “App Tracking Transparency” on iOS, and “Reset Advertising ID” / opt-out controls on Android).

For more information about how we use cookies and similar technologies, see our Cookie Policy.

8. Push Notifications and Communications

If you enable push notifications, we may send you notifications about new Content, recommendations, billing, security, or promotional messages. You can disable push notifications at any time through your device or operating system settings.

You may opt out of marketing emails by using the unsubscribe link in the message or by contacting support@swagtoons.net. Service-related messages (e.g., billing, security, or operational notices) may still be sent even if you opt out of marketing communications.

9. Data Retention

We retain information for as long as reasonably necessary to:

· provide the Service;

· meet legal, tax, and accounting obligations;

· resolve disputes;

· enforce our agreements; and

· comply with content licensing reporting obligations.

Retention periods vary depending on the type of data and the purpose for which it is processed. We may also retain and use aggregated or de-identified information that cannot reasonably be used to identify you.

10. Security

We use reasonable administrative, technical, and organizational measures designed to protect information. However, no security measure is perfect. You are responsible for maintaining the confidentiality of your account credentials and for any activity under your account.

11. International Data Transfers

We are established in Cyprus (EU) and process personal data primarily within the European Economic Area (EEA). Some of our service providers, content delivery networks, or content licensors are located in other countries, including the United States. Where we transfer personal data outside the EEA, your information may be processed in jurisdictions with different data protection laws.

Where required by applicable law (including in the EEA/UK), we will use appropriate safeguards for cross-border transfers (for example, Standard Contractual Clauses or equivalent contractual protections) to the extent applicable.

12. Your Privacy Rights

EEA/UK (GDPR)

If the GDPR applies to our processing of your personal data, you may have the right to:

· access your personal data;

· correct or update it;

· delete it;

· object to certain processing;

· restrict certain processing;

· request data portability; and

· withdraw consent where processing is based on consent.

You may also have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus, or with the data protection authority in your country of residence in the EEA or the UK.

U.S. State Privacy Laws

Depending on your state of residence (including California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and other states with consumer privacy laws), you may have rights such as:

· access to certain personal information we hold about you;

· deletion of certain personal information;

· correction of certain personal information;

· portability of certain personal information;

· opting out of the sale or sharing of personal information and targeted advertising;

· opting out of certain profiling, where applicable; and

· non-discrimination for exercising privacy rights.

Exercising rights. To submit a request, contact support@swagtoons.net. We may need to verify your identity and your request before completing it. Authorized agents may submit requests where permitted by law.

California Notice (CPRA)

This section applies to California residents to the extent the California Consumer Privacy Act, as amended by the CPRA (the “CPRA”), applies.

Categories of personal information we collect

We may collect the following categories (as defined by the CPRA), depending on how you use the Service:

· identifiers (e.g., email address, IP address, device identifiers, mobile advertising identifiers, account identifiers);

· internet or other electronic network activity information (e.g., viewing and usage data, interaction events, playback events, search queries);

· geolocation data (approximate location derived from IP);

· commercial information (e.g., subscription status, transaction identifiers, billing country, payment status, content purchased);

· audio, electronic, visual, or similar information (e.g., content of reviews or comments you submit, where applicable);

· inferences drawn from usage to personalize the Service (e.g., recommendations, audience segments, content preferences).

We do not intentionally collect Sensitive Personal Information as defined by the CPRA (such as government IDs or precise geolocation), and we do not use Sensitive Personal Information to infer characteristics about you.

Purposes of collection and use

We use personal information for the purposes described in the “How We Use Information” section of this Policy, including to operate the Service, personalize and improve it, process payments, provide support, prevent fraud and abuse, fulfill content licensing obligations, and comply with law.

Sources of personal information

We collect personal information from:

· you (directly, when you create an account, configure your profile, watch Content, or use the Service);

· your device or browser (automatically, when you interact with the Service); and

· service providers, application stores, payment processors, content licensors, and advertising and analytics partners (as described above).

Disclosures to service providers

We disclose personal information to service providers and contractors for business purposes, such as hosting, security, analytics, payment processing, attribution, content delivery, and customer support, consistent with the “How We Disclose Information” section.

“Sale” / “Sharing” and targeted advertising

We do not sell personal information for money. However, we may “share” personal information for cross-context behavioral advertising (as those terms are defined under the CPRA) if we use certain marketing or advertising technologies.

Right to opt out. California residents may opt out of the sale or sharing of personal information and targeted advertising by:

· using our cookie preference tools (choose “Reject Non-Essential” or adjust settings via “Manage Preferences”); and/or

· adjusting your device's mobile advertising controls (e.g., iOS App Tracking Transparency, Android opt-out); and/or

· contacting us at support@swagtoons.net with the subject line “California Privacy Rights”.

Retention

We retain personal information as described in the Data Retention section.

Non-discrimination

We will not discriminate against you for exercising your privacy rights.

Do Not Track / Global Privacy Control. We respond to browser-based opt-out preference signals (such as the Global Privacy Control) to the extent required by applicable law and supported by our systems.

13. Automated Decision-Making

The Service uses algorithmic processing to generate recommendations, rankings, and similar Outputs. These do not produce legal effects or similarly significant effects concerning you. Where automated decision-making with legal or similarly significant effects is implemented, we will provide additional information and rights as required by applicable law.

14. Changes to This Policy

We may update this Policy from time to time by posting the updated version on the Service. Where notice is required by applicable law, we will provide notice as required. Otherwise, it is your responsibility to review this Policy periodically. Continued use of the Service after changes are posted constitutes acceptance of the updated Policy.

15. Contact

GENART SYSTEMS LTD

28 Oktovriou, 367 MEDITERRANEAN COURT

1st floor, Office A5

3107, Limassol, Cyprus

Registration number HE 462727

Email: support@swagtoons.net.