Privacy Policy

Last updated: November 3, 2025

1. Introduction

SweetWater Holding UG (haftungsbeschränkt) ("we", "our", or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, and safeguard your information when you use Dealari (the "Service") in compliance with the General Data Protection Regulation (GDPR) and other applicable EU data protection laws.

2. Data Controller

Data Controller: SweetWater Holding UG (haftungsbeschränkt)

Address: Bunsenstraße 1, 22765 Hamburg, Germany

Email: info@dealsecure.io

Representative: Dr. Jan Niklas Sikorra (Managing Director)

3. Information We Collect

3.1 Personal Data You Provide

  • Account information (name, email address, company details)
  • Profile information and preferences
  • Deal and transaction data you upload to the platform
  • Communications with our support team
  • Payment information (processed by third-party payment providers)

3.2 Automatically Collected Data

  • Usage data and platform interactions
  • Device information and browser type
  • IP address and location data
  • Cookies and similar tracking technologies
  • Log files and error reports

3.3 Analytics Data

We use Plausible Analytics, a privacy-focused analytics service, to understand how visitors use our website.

  • Page views and user sessions (anonymized)
  • Referral sources and traffic patterns
  • Device and browser information (non-personal)
  • Geographic location (country/region level only)

Important: Plausible Analytics does not use cookies, does not track users across websites, and does not collect personal information. All data is anonymized and aggregated. Analytics are only loaded with your explicit consent through our cookie banner.

4. How We Use Your Information

4.1 Service Provision: To provide, maintain, and improve our Service

4.2 Communication: To communicate with you about your account and our services

4.3 Security: To protect against fraud and maintain security

4.4 Legal Compliance: To comply with legal obligations and enforce our terms

4.5 AI and Machine Learning: We use anonymized and aggregated data for:

  • Improving our AI algorithms and machine learning models
  • Benchmarking and performance analysis
  • Developing new features and functionalities
  • Industry research and analytics

Note: All data used for AI benchmarking is completely anonymized and cannot be traced back to individual users or companies.

5. Legal Basis for Processing (GDPR)

Consent: Where you have given clear consent for processing

Contract: Processing necessary for the performance of our service contract

Legitimate Interest: For service improvement, security, and business operations

Legal Obligation: To comply with applicable laws and regulations

6. Data Sharing and Third Parties

We may share your information with:

  • Service Providers: Third-party vendors who assist in operating our Service
  • Analytics Providers: Plausible Analytics for website usage analysis (anonymized data only)
  • Payment Processors: For processing payments securely
  • Legal Authorities: When required by law or to protect our rights
  • Business Transfers: In case of merger, acquisition, or asset sale

We never sell your personal data to third parties for marketing purposes.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These include encryption, access controls, and regular security assessments.

8. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this Privacy Policy, or as required by law. When data is no longer needed, we securely delete or anonymize it.

9. Your Rights Under GDPR

As a data subject in the EU, you have the following rights:

  • Right of Access: Request information about your personal data
  • Right to Rectification: Correct inaccurate or incomplete data
  • Right to Erasure: Request deletion of your personal data
  • Right to Restrict Processing: Limit how we use your data
  • Right to Data Portability: Receive your data in a portable format
  • Right to Object: Object to processing based on legitimate interests
  • Right to Withdraw Consent: Withdraw consent for processing

To exercise these rights, contact us at info@dealsecure.io

10. International Data Transfers

Your data may be transferred and processed in countries outside the European Economic Area (EEA). We ensure adequate protection through standard contractual clauses or other approved transfer mechanisms as required by GDPR.

11. Cookies and Tracking

We use cookies and similar technologies for:

Essential Cookies (Always Active)

  • Enable core website functionality
  • Remember your login status and preferences
  • Provide security and fraud protection
  • Store your cookie consent preferences

Analytics Cookies (Optional)

  • Understand how visitors use our website (via Plausible Analytics)
  • Measure website performance and user engagement
  • Identify popular content and features

Note: Plausible Analytics does not use cookies and respects user privacy by design.

You can manage your cookie preferences through our cookie banner that appears on your first visit, or through your browser settings. Withdrawing consent for analytics will not affect website functionality.

12. Children's Privacy

Our Service is not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware of such collection, we will delete the information immediately.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date.

14. Supervisory Authority

You have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal data violates the GDPR. The relevant supervisory authority for our company is the Hamburg Commissioner for Data Protection and Freedom of Information.

15. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at: info@dealsecure.io