Privacy notice — website and waitlist

Draft pending legal review.

Who is responsible

The data controller is Valnivo Labs, based in Luxembourg, which develops and runs Sway. Valnivo Labs is a trade name, not a registered company: if you need the controller named for a formal request or a complaint to a supervisory authority, ask at the address below and it will be given to you. Contact: sway@valnivo.eu.

What we collect

If you join the waitlist: your email address, the area you chose, the language of the page, and when you agreed. Nothing else. This website sets no tracking cookies and uses no analytics.

Why

To email you when Sway opens in your area. The legal basis is your consent, which you can withdraw at any time by writing to sway@valnivo.eu.

Bot protection

The form uses Cloudflare Turnstile to check that you’re human. Turnstile processes technical data such as your IP address and browser characteristics for that check only.

Where it is stored

In a Cloudflare D1 database restricted to the European Union. Cloudflare hosts this website and processes data on our behalf.

How long

Until we invite you, or 12 months at most, whichever comes first. Then it is deleted.

Your rights

You can ask to see, correct or delete your data, or withdraw consent, by writing to sway@valnivo.eu. You can also complain to the Commission nationale pour la protection des données (CNPD), cnpd.public.lu.

The app

The Sway app has its own privacy notice, shown before you create an account.

Audience measurement

Only if you click Accept, we use Google Analytics (Google Ireland Ltd.) to count visits and page views. It sets cookies (_ga) that last up to 2 years and sees your IP address, which Google does not store. Google may process the data in the United States under the EU–US Data Privacy Framework. Ads features and Google signals are off. The legal basis is your consent; you can withdraw it at any time with "Cookie settings" at the bottom of every page. Analytics data is kept for 2 months in Google Analytics.