In accordance with the provisions of the "Legal Notice" of the Website and the General Data Protection Regulation, we hereby provide you with the legally required information regarding the processing of personal data of users and customers that may be collected through browsing or contracting services through the Website.

In this regard, the Controller guarantees compliance with the current regulations on the protection of personal data, as reflected in Organic Law 3/2018 of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD GDD). It also complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GDPR).

The use of the Website implies acceptance of this Privacy Policy, as well as the conditions included in the Legal Notice.

Who is the Data Controller for your data?

Name: APATHEIA, S.L. (hereinafter referred to as Swapper)

Registered Office: Avenida Mirat, Salamanca, 37002 (Spain)

Tax ID: B44916856


What principles are applied to the processing of data?

In the processing of your personal data, the Controller shall apply the following principles in accordance with the requirements of the new European Regulation on the protection of personal data:

  • Lawfulness, fairness, and transparency: The Controller shall always require consent for the processing of your personal data, which may be for one or more specific purposes about which you will be informed with absolute transparency.
  • Data minimization: The Controller shall only request the data strictly necessary for the purpose(s) for which it is being collected.
  • Limitation of storage period: The data shall be kept for no longer than is necessary for the purpose(s) of the processing. In the case of subscriptions, the Controller shall periodically review the lists and delete those inactive records for a considerable period of time.
  • Integrity and confidentiality: Your data shall be processed in such a way as to ensure adequate security, confidentiality, and integrity. The Controller takes the necessary precautions to prevent unauthorized access or misuse of the data of its users by third parties.

For what purposes do we process your personal data?

When browsing, it is not necessary to provide any personal data. We process the personal data that you provide to us during the process of contracting services or purchasing products, regardless of the profile with which you carry out these actions, for the following purposes:

  • Carrying out the requested or contracted services, their invoicing, and collection. The provision of data for this purpose is obligatory, and failure to provide it would prevent the requested service from being provided.
  • Sending commercial communications about our products or services, unless you have expressed your opposition by any means. In any case, authorization to process your data for this purpose is voluntary, and your refusal would only result in not receiving commercial offers for our products or services.

When you connect to the Website to send an email to the Controller, subscribe to our newsletter, or make a purchase, it may be necessary to provide personal information for which the Controller is responsible. This information may include personal data such as your IP address, name and surname, physical address, email address, telephone number, and other information. By providing this information, you give your consent for your information to be collected, used, managed, and stored by, only as described in the Legal Notice and in this Privacy Policy.

The personal data and the purpose of the processing by the Controller are different depending on the information capture system:

  • Contact forms: The Controller, in the event that it requests personal data, may require: Name and surname, email address, telephone number, and website address in order to respond to your queries. For example, the Controller uses this data to respond to your messages, questions, complaints, comments, or concerns regarding the information included on the Website, the services provided through the Website, the processing of your personal data, matters relating to the legal texts included on the Website, as well as any other query you may have that is not subject to the conditions of the Website or contracting.
  • Subscription forms: The Controller may request your name and surname, email address, in order to manage the subscription list, send newsletters, promotions, and special offers.

There are other purposes for which the Controller processes your personal data:

  • To ensure compliance with the conditions set forth in the Legal Notice and the applicable law. This may include the development of tools and algorithms that help this Website to ensure the confidentiality of the personal data it collects.
  • To support and improve the services offered by this Website.
  • To analyze navigation. The Controller collects non-identifying data that is obtained through the use of cookies that are downloaded to your computer when you browse the Website, the characteristics and purpose of which are detailed in the Cookies Policy.
  • To manage social networks. The Controller may have a presence on social networks. If you become a follower on the Controller's social networks, the processing of personal data will be governed by this section, as well as by those terms of use, privacy policies, and access regulations that belong to the social network in question and that you have previously accepted. The Controller will process your personal data for the purpose of properly managing its presence on the social network, informing you of its activities, products, or services, as well as for any other purpose permitted by the regulations of the social networks.

How long will we keep your data?

The data necessary to carry out the request or request made by the Client, as well as the invoicing and collection of services, will be kept for as long as the agreement is in force. Once this relationship is terminated, if applicable, the data may be kept for the time required by applicable legislation and until any liabilities arising from the contract prescribed, which as a general rule will be a period of 6 years.

The data for sending commercial communications about our products or services will be kept indefinitely, unless you express your desire to delete them.

What is the legal basis for the processing of your data?

The legal basis for the processing of your data is the execution of the request or request made, in accordance with the terms and conditions set forth in these General Terms and Conditions of Contract.

The prospective offer of products and services is based on the consent requested, which you may revoke at any time. The withdrawal of said consent shall not affect the legality of the processing carried out prior to its withdrawal, nor shall it affect the execution of the contract and the data processing carried out for that purpose.

To contact the Controller, subscribe to a newsletter, or make comments on this Website, you must accept this Privacy Policy.

To which recipients will your data be disclosed?

The data will be disclosed to the following entities:

  • Competent Public Administrations, in cases provided for by law and for the purposes defined therein.
  • Financial entities through which the management of collections and payments is organized.
  • Where appropriate, third-party entities collaborating with in the provision of services contracted by the Client, for the purpose of managing said services.
  • Google Analytics, a web analytics service provided by Google, Inc., a Delaware company whose main office is at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States ("Google"). You can find more information at:
  • Crisp: A service provided by Crisp IM, a French company, with its main office at 2 boulevard de Launay in Nantes (44100), registered in Nantes, 833 085 806. You can find more information at

Security of personal data

To protect your personal data, the Controller takes all reasonable precautions and follows industry best practices to prevent their loss, misuse, unauthorized access, disclosure, alteration, or destruction.

The Website is hosted at The security of your data is guaranteed as they take all the necessary security measures for this purpose. You can consult their privacy policy for more information.

Web browsing

When browsing, non-identifying data may be collected, which may include your IP address, geolocation, a record of how services and sites are used, browsing habits, and other data that cannot be used to identify you.

The Website uses Google Analytics as a third-party analytics service. The Controller uses the information obtained to obtain statistical data, analyze trends, administer the site, study navigation patterns, and gather demographic information.

The pages of this Website may include embedded content (e.g., videos, images, articles, etc.). Embedded content from other websites behaves in the same way as if you had visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking code, and monitor your interaction using this code.

What are your rights when you provide us with your data?

Any person has the right to obtain confirmation as to whether or not we are processing personal data concerning them. Interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request their erasure when, among other reasons, the data are no longer necessary for the purposes for which they were collected. The exercise of these rights is personal and must therefore be exercised directly by the data subject.

Under the conditions provided for in the General Data Protection Regulation, data subjects may also request the restriction of the processing of their data or their portability, in which case we will only retain them for the exercise or defense of claims.

In certain circumstances and for reasons related to their particular situation, data subjects may object to the processing of their data. If you have given your consent for a specific purpose, you have the right to withdraw it at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal. In these cases, we will stop processing the data or, where appropriate, stop processing them for that specific purpose, unless there are compelling legitimate grounds or for the exercise or defense of possible claims.

All the aforementioned rights can be exercised through the contact details provided at the beginning of this clause.

If you believe that your rights have been violated, especially if you have not obtained satisfaction in the exercise of your rights, you may file a complaint with the Spanish Data Protection Agency (contact information available at or another competent supervisory authority. You can also obtain more information about your rights by contacting these organizations.

To exercise your rights of access, rectification, cancellation, portability, and opposition, you must send an email to along with valid proof of identity, such as a photocopy of your ID card or equivalent.

Acceptance and consent

As a User of the Website, you declare that you have been informed of the conditions regarding the protection of personal data, and you accept and consent to the processing of such data by the Controller in the manner and for the purposes indicated in this Privacy Policy.

Accuracy and truthfulness of personal data

You agree that the data provided to the Controller are correct, complete, accurate, and up-to-date, and you undertake to keep them properly updated.

As a User of the Website, you are solely responsible for the accuracy and correctness of the data you submit to the site, relieving the Controller of any responsibility in this regard.


To exercise your rights of access, rectification, cancellation, portability, and opposition, you must send an email to along with valid proof of identity, such as a photocopy of your ID card or equivalent.

The exercise of your rights does not include any data that the Controller is obliged to keep for administrative, legal, or security purposes.

Changes to the Privacy Policy

The Controller reserves the right to modify this Privacy Policy to adapt it to legislative or jurisprudential developments, as well as to industry practices.

These policies will be in effect until they are modified by duly published ones.

Cookie Policy

For this Website to function properly, it needs to use cookies, which are information stored in your web browser.

On the Cookie Policy page, you can consult all the information regarding the collection policy, the purpose, and the processing of cookies.