Legal

Privacy Policy

Last updated: August 21, 2026

At Sway Pakistan, we value your privacy and are committed to protecting your personal information. This Privacy Policy explains how Sway Mah (SMC Private) Limited ("Sway", "we", "our", or "us") collects, uses, stores, shares, and safeguards your personal data when you visit sway.pk, create an account, or place an order through our platform.

Some products available through Sway are intended exclusively for adults aged 18 years or older, while other products are not age-restricted. Where an order includes an age-restricted product, we may be required to verify that the customer meets the applicable age requirement.

By accessing or using our website, you acknowledge that you have read and understood this Privacy Policy and agree to the practices described below.

1. Information We Collect

To provide our services efficiently and securely, we may collect the following types of information. Information You Provide When you use our website, you may provide us with: • Full name • Phone number • Email address • Delivery address • Account information • Order history and purchase preferences • Delivery instructions • Customer support enquiries and communications submitted through email, WhatsApp, contact forms, or social media Age Verification Some products available through Sway are subject to age restrictions. When you order an age-restricted product, we may request information necessary to verify that you are at least 18 years old, including: • Date of birth • Confirmation that you are 18 years of age or older • Government-issued identification, such as CNIC, where required to verify your age before completing an order Age verification is only applied where necessary for an age-restricted product or where required by applicable law. Information Collected Automatically When you browse our website, we may automatically collect certain technical and usage information, including: • IP address • Browser type • Device type • Operating system • Pages visited • Referral source • Session activity • Cookies and similar technologies More information about cookies is provided in Section 7. Payment Information To ensure secure online transactions, all card payments are processed through licensed third-party payment providers and acquiring banks. Sway does not collect, store, or have access to: • Full card numbers • CVV codes • Banking credentials We receive only payment confirmation and masked transaction references necessary to process and reconcile transactions.

2. How We Use Your Information

We use your personal information to provide, manage, improve, and protect our services. This may include: • Processing, fulfilling, and delivering your orders • Managing your Sway account • Providing order confirmations and delivery updates • Verifying your age where an order includes an age-restricted product • Processing payments, refunds, and related transactions • Responding to customer enquiries, complaints, and support requests • Preventing fraud, abuse, and unauthorized transactions • Improving our website, services, product range, and customer experience • Sending promotional communications where you have opted in • Complying with applicable laws, regulations, and lawful requests from competent authorities We do not sell or rent your personal information to third parties.

3. Legal Basis for Processing

We process personal information where necessary for: • Performing our contractual obligations, including fulfilling and delivering your orders • Obtaining and acting on your consent, such as when you choose to receive marketing communications • Complying with applicable legal and regulatory obligations • Pursuing legitimate business interests, including fraud prevention, website security, service improvement, and customer support, while taking your privacy rights into consideration Sway manages personal information in accordance with applicable laws of Pakistan, including the Prevention of Electronic Crimes Act, 2016 (as amended), while seeking to follow internationally recognized privacy principles such as: • Purpose limitation • Data minimization • Accuracy • Storage limitation • Security and confidentiality

4. Data Security

Protecting your personal information is a priority. We implement appropriate administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, alteration, disclosure, loss, or misuse. These measures may include: • Secure servers • Restricted staff access • Password-protected systems • SSL/TLS encryption • Internal access controls • Periodic security monitoring and reviews All online card payments are securely processed by PCI-DSS-compliant payment partners. Sensitive card information is not stored on or handled directly by Sway's systems. If a security incident occurs that affects your personal information, we will take appropriate steps to investigate, mitigate, and respond to the incident and notify affected individuals or relevant authorities where required by applicable law.

5. Data Retention

We retain personal information only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy and to meet applicable legal, accounting, tax, and business requirements. Account and Order Information We retain account and order information while your account remains active and for up to 3 years afterward, where necessary for tax, accounting, legal, dispute-resolution, fraud-prevention, or other legitimate business purposes. Age Verification Records Where age verification is required for an age-restricted product, related records may be retained for as long as reasonably necessary to demonstrate compliance with applicable age-restriction obligations. Marketing Information Marketing-related information is retained until you unsubscribe, withdraw your consent, or where otherwise no longer required for the relevant purpose. When personal information is no longer required, we will take reasonable steps to securely delete it or anonymize it where appropriate.

6. Sharing Your Information

We share personal information only where reasonably necessary to operate our business, provide our services, or comply with applicable legal obligations. This may include sharing information with: Delivery and Logistics Partners To fulfil and deliver your order, we may provide delivery partners with information such as: • Name • Phone number • Delivery address • Relevant delivery instructions Where an order contains an age-restricted product, delivery partners may also be required to follow applicable age-verification or delivery procedures. Payment Providers Licensed payment gateways and acquiring banks may receive the information necessary to process payments, refunds, and related transactions. Technology and Service Providers We may use trusted hosting providers, technology companies, cloud services, and IT providers to operate, maintain, secure, and improve our website and services. These providers are expected to handle personal information only for the services they provide to Sway and in accordance with applicable confidentiality and security requirements. Legal and Regulatory Authorities We may disclose personal information where required by applicable law, court order, regulatory requirement, or a valid legal request from a competent authority. We do not authorize third parties to use your personal information for purposes unrelated to the services they provide to Sway, except where otherwise required or permitted by law.

7. Cookies

Sway uses cookies and similar technologies to help operate and improve our website. These technologies may be used to: • Keep you signed into your account • Remember items in your shopping cart • Support website functionality • Analyze website traffic and performance • Understand how visitors use our website • Improve your overall browsing experience You can manage or disable cookies through your browser settings. However, disabling certain cookies may affect website functionality, and some features, including account functions or checkout, may not work correctly.

8. Your Privacy Rights

Subject to applicable law, you may have the right to: • Request access to the personal information we hold about you • Ask us to correct inaccurate or incomplete information • Request deletion of personal information where it is no longer required for a lawful purpose • Withdraw consent for marketing communications at any time • Object to certain forms of processing To exercise any applicable privacy rights, please contact us using the information provided in Section 11. We will review and respond to your request within a reasonable timeframe and in accordance with applicable law.

9. Age-Restricted Products

Sway provides a number of products intended exclusively for adults aged 18 years or older. However, not all products available through Sway are age-restricted. Where a customer purchases an age-restricted product, Sway may require age verification before completing or delivering the order. This may include requesting confirmation of age or, where necessary, a valid government-issued identification document such as a CNIC. We do not knowingly: • Sell age-restricted products to individuals under 18 • Collect personal information from minors for the purpose of purchasing age-restricted products • Market age-restricted products to individuals under 18 If we become aware that personal information has been collected from an individual under the applicable age requirement in connection with an age-restricted product, we will take reasonable steps to address and delete the information where appropriate and legally permissible. Sway offers products in accordance with applicable laws and regulations and does not knowingly offer, promote, or sell illegal or prohibited products.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our business practices, website, technology, services, or applicable legal requirements. When changes are made, we will publish the updated version on this page and revise the Last Updated date accordingly. We encourage you to review this Privacy Policy periodically to remain informed about how we handle personal information. Your continued use of the website after an updated Privacy Policy has been posted may constitute acceptance of the revised Policy, to the extent permitted by applicable law.

11. Contact Us

If you have questions, requests, concerns, or complaints regarding this Privacy Policy or the way Sway handles your personal information, please contact us. Sway Mah (SMC Private) Limited Trading as Sway Pakistan Registered Office: 2B, Sector B, Phase 5, DHA Lahore, 54810, Pakistan Email: privacy@sway.pk Website: https://sway.pk Operating Hours: Open 24 hours a day, 365 days a year Corporate Hours: 11:00 AM – 5:00 PM