Privacy Policy

This Privacy Policy explains how Swarming Labs LTD (“Sparkling”, “we”, “us”) collects, uses, shares and protects personal data when you visit this website or use Sparkling crypto, the trading platform with an agent that runs inside Telegram and on the web. It includes information specific to users in Nigeria.

Privacy policy sparkling

1. Data Controller

Swarming Labs LTD Intershore Chambers, Road Town, Tortola British Virgin Islands Email: [email protected] Data protection officer: [email protected]

2. Information We Collect

Information collected automatically

  • Transaction data: quotes, signed transactions and transaction hashes.
  • Technical data: device type, operating system, Telegram client version, IP address and approximate region. IP addresses are kept for a maximum of 30 days, or 90 days during a security investigation.
  • Usage data: feature use, error logs and performance metrics.

Information from partners

  • Wallet infrastructure (Turnkey): wallet addresses and authentication events.
  • Routing and settlement partners: execution, routing and pricing data.
  • Sanctions screening providers: screening results.

On-chain information Public blockchain data, such as wallet addresses, amounts and timing, is visible to anyone. We analyse it to run the Service and meet compliance obligations.

This website This website does not use advertising or tracking cookies and has no forms or comments. Our hosting and security provider processes technical data (IP address, browser, pages requested) to deliver and protect the site. Visit statistics are collected without cookies. See the Cookie Policy for details.

3. How We Use Information

  • To provide the Service: preparing quotes, executing the trades you confirm, showing balances.
  • To secure your account: verifying logins and detecting suspicious access.
  • To communicate with you: transaction notices and support replies.
  • To improve the Service: analysing aggregated use and fixing errors.
  • To prevent fraud and abuse: detecting bots, account takeovers and market manipulation.
  • To comply with the law: responding to lawful requests and keeping required records.

We do not sell personal data and do not use it for marketing without your consent.

4. How We Share Information

We share data only with:

  • service providers (cloud hosting, email, analytics, customer support), bound by data processing agreements;
  • partners integrated with the Service, such as wallet infrastructure, liquidity and settlement providers, each under its own privacy policy;
  • authorities, where the law requires it;
  • a buyer or successor in a merger or acquisition, under the same level of protection;
  • anyone else only with your consent.

5. International Transfers

Sparkling is provided from outside Nigeria, so your data is processed abroad. Where we transfer personal data out of Nigeria, we rely on safeguards permitted by the Nigeria Data Protection Act 2023, such as contractual protections with our providers, or on your consent.

6. How Long We Keep Data

Category Retention
Account information While the account is active, plus 12 months
Transaction records 7 years from the transaction date
Support messages 3 years from the last contact
Technical logs and IP addresses 30 days (90 days for security investigations)
Aggregated, de-identified statistics No fixed limit

7. Your Rights in Nigeria

Under the Nigeria Data Protection Act 2023 you have the right to:

  • be informed about how your data is used;
  • access a copy of your personal data;
  • correct inaccurate data;
  • ask for deletion, subject to legal retention duties;
  • restrict or object to processing;
  • receive your data in a portable format;
  • withdraw consent at any time;
  • not be subject to a decision based solely on automated processing that has a significant effect on you.

To use these rights, email [email protected] from the address linked to your account. We reply within 30 days. If you are not satisfied with our response, you can complain to the Nigeria Data Protection Commission (NDPC).

8. Security

We protect data with encryption in transit and at rest, multi-factor authentication and role-based access for internal systems, logging and regular security testing. No system is completely secure. Report security issues to [email protected].

9. Automated Processing

The agent prepares trade proposals automatically, but every trade needs your confirmation. Automated systems also flag possible fraud and sanctions matches; decisions with a significant effect on you, such as suspending an account, are reviewed by a person.

10. Children

The agent prepares trade proposals automatically, but every trade needs your confirmation. Automated systems also flag possible fraud and sanctions matches; decisions with a significant effect on you, such as suspending an account, are reviewed by a person.

12. Changes

We may update this policy. Material changes are announced in the app or by email before they take effect.

13. Contact

Purpose Contact
General questions [email protected]
Privacy and data rights [email protected]
Legal notices [email protected]

Postal address: Swarming Labs LTD, Intershore Chambers, Road Town, Tortola, British Virgin Islands.

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