SWAPVEND PRIVACY POLICY

Effective Date: [01.08.2026]
Last Updated: [01.08.2026]
Website: swapvend.co.za
Privacy Contact: admin@swapvend.co.za

 

 


1. Introduction

SwapVend is an ecosystem designed to connect individuals, entrepreneurs, businesses and opportunities through participation, exchange, development and collaboration. We respect the privacy of the people who use SwapVend and recognise the importance of protecting personal information entrusted to us.

 

This Privacy Policy explains:

  • what personal information SwapVend collects;

  • why we collect it;

  • how it is used;

  • how it is stored and protected;

  • how information is used by our AI mentor, Chomi;

  • how private interactions between users are handled;

  • what information may be shared with service providers;

  • how aggregated information may be used with partners;

  • how users can manage or delete their information; and

  • the rights available to users under applicable privacy and data-protection laws, including the Protection of Personal Information Act 4 of 2013 (“POPIA”).

By registering for and using SwapVend, you acknowledge that you have read and understood this Privacy Policy.

 

 


2. Who this policy applies to

This Privacy Policy applies to individuals who:

  • register for a SwapVend account;

  • create or maintain a SwapVend profile;

  • participate in SwapVend Journeys;

  • communicate with other users;

  • participate in trading, exchanges or other ecosystem activities;

  • use Chomi;

  • interact with the SwapVend website or platform; or

  • otherwise provide information to SwapVend.

SwapVend is intended for individuals who are 18 years of age or older.

You must not create or maintain a SwapVend account if you are under 18.

 

 


3. Our approach to personal information

SwapVend is designed around a distinction between individual user information and collective ecosystem information.

 

Your individual information is used primarily to:

  • establish and maintain your account;

  • identify and validate your participation;

  • support safety and accountability within the ecosystem;

  • enable you to interact with other users;

  • provide relevant platform functionality;

  • support your participation in Journeys and programmes; and

  • provide relevant contextual assistance through Chomi.

SwapVend may also analyse information across the wider ecosystem to produce aggregated, statistical or de-identified information about the market and participating community. Our intention is that external partners receive ecosystem-level information rather than individual user profiles.

 

We do not intend to sell or routinely provide your individually identifiable profile information to external partners for their independent use.

 

 


4. Information we collect

The information we collect depends on how you use SwapVend. It may include the following categories.

 

4.1 Identity and account information

We may collect:

  • first name;

  • surname;

  • date of birth;

  • gender;

  • racial identity;

  • nationality;

  • province;

  • city;

  • contact number;

  • account credentials and account-related information.

Some of this information supports account identification and validation. Because SwapVend enables users to interact, communicate and potentially trade or exchange with other individuals, maintaining identifiable accounts helps support accountability, safety and responsible participation within the ecosystem.

 


4.2 Profile and personal context

You may provide information such as:

  • your biography;

  • what you do;

  • what you offer;

  • your business or side-hustle status;

  • your business type;

  • your interests;

  • your goals;

  • your interest in incubation and support programmes;

  • your interest in SwapVest or other SwapVend opportunities; and

  • other information you voluntarily include in your profile.

This information helps SwapVend understand the nature of your participation and may be used to provide more relevant services and opportunities.

 


4.3 Demographic information

SwapVend may collect demographic information including:

  • age/date of birth;

  • gender;

  • racial identity;

  • nationality;

  • geographic location.

Where a “Prefer not to say” option is provided, you may choose not to provide the relevant information. Not every profile or lifestyle question is mandatory. Some demographic information may be used to understand representation within the SwapVend ecosystem and to develop aggregated demographic or market-level insights.

 


4.4 Racial identity

SwapVend may ask users to provide racial identity information. We recognise that racial identity is sensitive personal information under applicable South African privacy law. SwapVend may use this information for legitimate platform and ecosystem purposes, including:

  • supporting user identification and validation;

  • understanding representation within the SwapVend ecosystem;

  • understanding the social and demographic environment in which users operate;

  • supporting contextual understanding relevant to Chomi; and

  • producing aggregated demographic and ecosystem statistics.

Where available, users may select “Prefer not to say”. SwapVend does not intend to use racial identity to make discriminatory decisions about users or to determine a user’s access to opportunities solely on the basis of their racial identity.

 

 


5. Business and Journey information

SwapVend Journeys may ask users to provide information about themselves, their businesses, activities, goals and development. This may include:

  • business status;

  • business maturity or stage;

  • business activities;

  • products or services;

  • goals;

  • challenges;

  • capabilities;

  • development needs;

  • self-assessments;

  • actions;

  • tasks;

  • milestones;

  • Journey progress; and

  • additional information voluntarily supplied during a Journey.

Journey information is generally based on information declared or supplied by the user. Users are responsible for ensuring that information they provide is reasonably accurate and appropriate for the purpose for which it is supplied. Journey information may be used to:

  • operate and administer Journeys;

  • provide development and business support;

  • track progress;

  • personalise relevant platform experiences;

  • provide contextual information to Chomi where applicable; and

  • contribute to aggregated ecosystem insights.

 


6. Lifestyle and financial information

SwapVend may offer optional questions relating to a user’s circumstances, including information about:

  • employment;

  • unemployment;

  • retirement;

  • education;

  • primary income-earner status;

  • government grants;

  • investment funds;

  • personal banking arrangements;

  • business banking arrangements;

  • tax registration; and

  • money-management characteristics.

These questions are not necessarily required. This information is intended to help SwapVend understand the broader characteristics of its participating ecosystem and, where appropriate, support relevant platform or programme development. Users should therefore not assume that Chomi has access to every piece of information contained within their SwapVend profile.

 


7. Information visibility within SwapVend

Some profile information may be made visible to other registered SwapVend users. This may include information such as:

  • first name;

  • surname;

  • province;

  • city;

  • contact information;

  • biography; and

  • other information intentionally included in the user’s visible profile.

Other information may remain private to the user and authorised SwapVend functionality. SwapVend’s purpose in making selected information visible is to support:

  • user identification;

  • communication;

  • trust;

  • accountability;

  • networking;

  • participation; and

  • safer interaction between ecosystem participants.

The exact visibility of individual profile fields may depend on the settings and functionality of the SwapVend platform. Users should therefore review their profile visibility settings carefully before providing information.

 

 


8. Private messages, trading and exchanges

SwapVend allows users to communicate with one another through private direct messages. Trading, exchanges and other user-to-user discussions are intended to take place through private communications between participating users and are not intended to be publicly displayed. These communications may be processed and stored as necessary to:

  • provide the messaging service;

  • facilitate communication between users;

  • maintain platform security;

  • prevent misuse;

  • investigate abuse or suspicious activity;

  • assist with disputes or safety matters; and

  • comply with applicable legal obligations.

Users should exercise appropriate care when sharing personal, financial, business or other sensitive information directly with another user. SwapVend cannot guarantee the conduct of another individual after information has voluntarily been disclosed to that person through a private interaction.

 

 


9. Chomi — SwapVend’s AI mentor

SwapVend provides an AI mentor called Chomi. Chomi is designed to provide more relevant and contextual assistance by considering information that SwapVend makes available to it about the user. Chomi’s intended contextual understanding primarily relates to:

  • who the user is;

  • where the user operates;

  • what the user does or offers;

  • relevant business or Journey information;

  • relevant information the user has provided during interaction with Chomi; and

  • the context of the user’s current question.

The purpose is contextual personalisation, rather than creating an extensive psychological or behavioural profile of the user.

 

 


10. Information Chomi does not currently receive

Chomi does not currently receive unrestricted access to all information stored within a user’s SwapVend profile. In particular, SwapVend’s current Chomi configuration does not provide Chomi with the user’s lifestyle and financial segmentation information, including information relating to:

  • employment status;

  • government grants;

  • investment funds;

  • banking status;

  • tax registration; or

  • similar lifestyle segmentation information.

Chomi therefore should not be understood as having unrestricted access to a user’s complete SwapVend account.

 

 


11. How Chomi’s AI processing works

Chomi is delivered through the AI Engine WordPress integration by Meow Apps and uses OpenAI’s API services to generate AI responses.

In simplified form: SwapVend → AI Engine → OpenAI API → Chomi response → SwapVend user

 

Information relevant to the user’s request and the context made available to Chomi may therefore be transmitted to OpenAI for processing. AI Engine functions as the technical integration layer within the SwapVend WordPress environment. AI Engine’s documentation states that its data is stored within the WordPress environment rather than being stored on Meow Apps’ own online infrastructure.

 

 


12. Chomi conversational memory

SwapVend uses a rolling persistent conversational memory for Chomi. The current configuration maintains the most recent 20 messages relevant to the applicable Chomi conversation/history segments in order to help Chomi maintain conversational continuity. As new messages are added, older messages fall outside the active persistent Chomi memory. This 20-message limit relates to SwapVend’s configured Chomi conversational context.

 

It should not be interpreted as a guarantee that an external service provider has identical retention limits, because external service providers operate according to their own applicable data-processing and retention arrangements.

 

 

 


13. OpenAI processing

Chomi uses the OpenAI API to process information required to generate responses. OpenAI currently states that, for its business services and API platform, inputs and outputs are not used to train or improve its models by default. Organisations may explicitly opt into certain data-sharing mechanisms through their OpenAI settings. SwapVend does not intend to use Chomi as a mechanism for providing individual user profiles to OpenAI for model training.

 

OpenAI also states that its business/API data is encrypted in transit and at rest and that qualifying organisations can access additional data-retention controls. Because OpenAI is an independent service provider, information transmitted to OpenAI is subject to OpenAI’s applicable terms, policies and data-processing arrangements. Users should not intentionally provide Chomi with information that they would not want processed by an external AI service.

 

 


14. AI-generated information

Chomi’s responses are generated using artificial intelligence. Chomi is intended to provide guidance, information and contextual assistance. Its responses should not automatically be treated as:

  • professional legal advice;

  • professional financial advice;

  • medical advice;

  • tax advice;

  • guaranteed business advice;

  • an offer or promise from SwapVend; or

  • a guarantee of a particular outcome.

Users remain responsible for decisions they make based on information provided by Chomi. Where a matter has significant legal, financial, regulatory, medical or other professional consequences, users should obtain appropriate professional advice.

 

 


15. AI access to SwapVend

Chomi is intentionally limited to the information and functionality made available to it by SwapVend. The current Chomi architecture does not use MCP or provide unrestricted AI access to the SwapVend WordPress database. Chomi is not intended to independently search or expose arbitrary private user records. SwapVend may change or expand the capabilities of Chomi in the future. Where material changes affect the way personal information is processed, this Privacy Policy may be updated accordingly.

 

 


16. Information shared with external partners

SwapVend’s partner model is based on ecosystem-level information rather than individual user information. SwapVend does not routinely provide external partners with individually identifiable user records such as:

  • individual profiles;

  • individual Journey records;

  • individual Chomi context;

  • individual Chomi conversations;

  • private user messages;

  • individual trading histories; or

  • individually identifiable user datasets.

Instead, SwapVend may create aggregated or de-identified information from information across the ecosystem.

This may include:

  • demographic statistics;

  • geographic statistics;

  • business-stage statistics;

  • participation statistics;

  • segment statistics;

  • market trends;

  • ecosystem trends;

  • category statistics; and

  • other market-level representations.

This information may be used to represent the nature and characteristics of the SwapVend ecosystem to partners and other legitimate stakeholders.

 

 


17. Aggregated and de-identified information

SwapVend may combine information from multiple users to create statistical or market-level information. Where information is aggregated or de-identified, SwapVend’s intention is that the resulting information cannot reasonably be used to identify an individual user.

Examples may include:

  • the percentage of users operating in a particular province;

  • the number of participating businesses within a broad business category;

  • aggregate business-stage distributions;

  • demographic representation across the ecosystem;

  • broad market participation trends.

SwapVend will seek to avoid unnecessarily exposing small or highly specific groups where doing so could create a reasonable risk of identifying an individual. Aggregated or de-identified information may continue to be used after an individual account has been deleted where the information can no longer reasonably be associated with that individual.

 

 


18. What SwapVend does not sell

SwapVend does not operate on a model of selling individual user profiles to external partners. We do not intend to sell individually identifiable information such as:

  • user profiles;

  • contact details;

  • individual business information;

  • Journey records;

  • Chomi context;

  • private messages; or

  • individual trading information

to external partners for their independent marketing or commercial use. Where partners receive information from SwapVend, the intended model is aggregated, de-identified or ecosystem-level representation.

 

 


19. Service providers and technology partners

SwapVend uses third-party technology and service providers to operate the platform. These may include:

 

GoDaddy

GoDaddy provides hosting and related infrastructure for the SwapVend platform. SwapVend’s website and WordPress environment are hosted using GoDaddy services. GoDaddy states that it stores personal data on its systems and with trusted service providers and that personal data may be transferred internationally as part of its global operations.

 

AI Engine / Meow Apps

SwapVend uses AI Engine by Meow Apps as the WordPress integration used to operate Chomi. AI Engine provides the technical connection between SwapVend and the configured AI provider.

 

OpenAI

OpenAI provides the AI services used to generate Chomi responses.

 

Google Analytics

SwapVend uses Google Analytics to understand website usage, including session and page-visit information.

 

Burst Statistics

SwapVend uses Burst Statistics to understand website usage, including session and page-visit information.

 

MemberPress

MemberPress is used as part of SwapVend’s membership/account functionality.

 

BuddyPress

BuddyPress is used for user profiles, social functionality and private user-to-user communication. These providers may process information as necessary to provide their respective services.

 

 

 


20. Website analytics

SwapVend currently uses Google Analytics and Burst Statistics for website usage analysis. The current intended use includes information relating to:

  • website sessions;

  • pages visited; and

  • session duration.

Analytics are used to understand how the platform is being used and to improve the website and user experience. Analytics information is separate from the individual profile and Journey information used to operate the SwapVend ecosystem.

 

 


21. Cookies and similar technologies

SwapVend and its technology providers may use cookies, session identifiers and similar technologies necessary to:

  • operate the website;

  • maintain account sessions;

  • support security;

  • remember relevant settings;

  • analyse website usage; and

  • improve the platform.

Where applicable, users may manage certain cookie or analytics preferences through their browser or available website controls. Disabling certain cookies may affect the functionality of parts of SwapVend.

 

 


22. How information is stored

SwapVend operates primarily within a WordPress-based environment hosted through GoDaddy. Information may be stored within:

  • WordPress user accounts;

  • profile and metadata records;

  • Journey records;

  • BuddyPress records;

  • MemberPress records;

  • AI Engine-related records;

  • messaging records;

  • platform databases; and

  • associated hosting infrastructure.

The exact technical storage location may vary depending on the functionality being used and the relevant service provider.

 

 


23. International processing

Some SwapVend technology providers operate internationally. As a result, personal information may be processed or stored in countries outside South Africa. For example, GoDaddy states that it operates globally and may transfer personal information internationally in order to provide its services. OpenAI likewise operates global infrastructure for its API services.

 

Where personal information is transferred outside South Africa, SwapVend will seek to do so in accordance with applicable data-protection requirements and appropriate contractual, technical or organisational safeguards.

 

 


24. Security

SwapVend takes reasonable technical and organisational measures to protect personal information against:

  • unauthorised access;

  • loss;

  • misuse;

  • alteration;

  • disclosure;

  • destruction; and

  • other inappropriate processing.

Security measures may include:

  • account authentication;

  • access controls;

  • hosting security;

  • software/plugin updates;

  • database protections;

  • administrative controls;

  • monitoring and maintenance; and

  • other appropriate technical measures.

No internet-based system can be guaranteed to be completely secure. Users are responsible for protecting their account credentials and should notify SwapVend if they believe their account has been compromised.

 

 


25. Retention of personal information

SwapVend generally retains personal information for as long as it is required to:

  • provide the platform;

  • maintain the user’s account;

  • provide requested services;

  • support Journey participation;

  • maintain security;

  • prevent fraud or misuse;

  • resolve disputes;

  • comply with legal obligations; or

  • fulfil other legitimate operational purposes.

SwapVend does not intend to retain personal information indefinitely when it is no longer required. Specific retention periods may vary according to the type of information and the purpose for which it is processed. Third-party providers may have their own applicable retention periods and policies.

 

 


26. Account deletion

Users can delete their SwapVend account through the account options provided on the platform. When an account is deleted, SwapVend’s current process is intended to delete the personal information associated with that account from the SwapVend platform.

 

This may include information associated with:

  • the user account;

  • profile;

  • Journey participation;

  • user metadata; and

  • other associated personal information held within the platform.

Information that has already been irreversibly aggregated or de-identified and can no longer reasonably be associated with the individual may remain as part of historical ecosystem statistics. Where information must be retained to comply with a legal obligation, resolve a dispute, maintain security or otherwise meet a lawful requirement, it may be retained for the applicable period.

 

 


27. Accuracy of information

SwapVend relies significantly on information provided by users.

Users should therefore:

  • provide accurate information;

  • update information when circumstances change;

  • avoid providing information that belongs to another person without appropriate authority; and

  • correct information that is inaccurate or outdated.

Users may update applicable profile information through their account.

 

 


28. User rights

Subject to applicable law, users may have rights relating to their personal information, including the right to:

  • request access to personal information held about them;

  • request correction of inaccurate or incomplete information;

  • request deletion where legally applicable;

  • object to or restrict certain forms of processing where applicable;

  • withdraw consent where processing is based on consent;

  • ask questions about how their information is being processed;

  • raise concerns about the use of their personal information; and

  • lodge a complaint with the relevant regulatory authority where applicable.

Requests should be directed to: admin@swapvend.co.za

SwapVend may need to verify the identity of a person making a request before releasing, correcting or deleting personal information.

 

 


29. Consent and optional information

Where SwapVend asks for optional information, users may choose whether to provide it. Where a field includes a “Prefer not to say” option, users may choose not to provide that information. The absence of optional information may affect the ability of SwapVend to provide certain personalised features, opportunities or contextual experiences, but users should not be required to provide optional information merely because it may improve personalisation.

 

Where consent is the appropriate legal basis for processing, users may withdraw consent subject to applicable legal and operational limitations.

Withdrawal of consent does not necessarily affect processing that was lawfully completed before consent was withdrawn or processing that is permitted on another lawful basis.

 

 


30. Special personal information

Certain information collected by SwapVend may constitute special personal information under applicable South African law. This may include racial identity and other information depending on the circumstances in which it is collected or used. SwapVend will seek to process such information only for appropriate and lawful purposes and will apply appropriate safeguards to its handling. Users may decline to provide demographic information where a “Prefer not to say” option is available.

 

 


31. Information relating to other people

Users should not provide SwapVend, Journeys or Chomi with another person’s personal information unless they have a lawful reason and appropriate authority to do so.

Users should be particularly careful when entering:

  • another person’s contact details;

  • confidential business information;

  • private financial information;

  • customer information;

  • employee information; or

  • other information that belongs to another individual.

 

 


32. Children

SwapVend is intended for individuals aged 18 years and older. We do not knowingly permit individuals under 18 to create or maintain SwapVend accounts. If we become aware that an individual under 18 has created an account, we may take appropriate steps to remove the account and associated information.

 

 


33. Changes to this Privacy Policy

SwapVend may update this Privacy Policy from time to time. Changes may be necessary because of:

  • changes to the SwapVend platform;

  • new services or functionality;

  • changes to Chomi;

  • changes to technology providers;

  • changes to applicable law;

  • changes to data-processing practices; or

  • improvements to our privacy practices.

The latest version will be published on the SwapVend website. Where a change materially affects how personal information is processed, SwapVend will seek to provide appropriate notice where required.

 

 


34. Privacy questions and complaints

If you have questions, concerns or requests regarding the handling of your personal information, please contact us on – Email: admin@swapvend.co.za

 

SwapVend intends to establish formal privacy governance and appoint/formally designate an appropriate Information Officer as the platform develops. Until such formal appointment is made, privacy-related queries may be directed to the above contact address. Where a user remains dissatisfied after raising a privacy concern with SwapVend, they may have the right to approach the relevant South African privacy regulator or other competent authority.

 

 


35. Responsible use of SwapVend

SwapVend is an ecosystem involving interaction between individuals and businesses. Users should therefore understand that information voluntarily disclosed to another user through:

  • private messages;

  • trading discussions;

  • business discussions;

  • Journey activities; or

  • other direct interactions

may subsequently be known to that person. SwapVend seeks to provide appropriate platform controls and privacy protections, but cannot guarantee the behaviour of another participant outside the technical controls of the platform. Users should exercise reasonable judgement when sharing confidential information.

 

 


36. Our commitment to users

SwapVend’s privacy approach can be summarised as follows:

Your information helps establish who you are, supports safer participation, helps us understand what you offer, and enables us to provide relevant services and assistance.

Chomi uses relevant contextual information to provide more useful and locally appropriate assistance.

Your private interactions remain private within the platform and are not intended to become partner data.

We do not intend to sell your individual profile to external partners.

Where SwapVend develops market or ecosystem intelligence, our intended model is to use aggregated or de-identified information rather than individual user profiles.

You can delete your SwapVend account through the platform’s account options.

You can contact us at admin@swapvend.co.za with questions or requests concerning your personal information.

 

 


37. Contact details

SwapVend

Website: swapvend.co.za

Privacy enquiries: admin@swapvend.co.za

Policy status: SwapVend Privacy Policy v2

New Report

Close