Privacy Notice
Mondial Change SA processes the personal data of its users responsibly and transparently. This Privacy Notice describes which data we collect, how we use it, and with whom we share it in connection with the online currency exchange service offered under the Swimo brand through swimo.swiss. This document has been drafted in accordance with the Swiss Federal Act on Data Protection (nFADP), effective as of 1 September 2023, and takes into account the provisions of Regulation (EU) 2016/679 (GDPR) for users residing in the European Union. We invite you to read this Privacy Notice together with our Terms and Conditions and our Cookie Notice.
1. Third-Party Websites and Services
The website swimo.swiss may contain links to websites or services operated by independent third parties. Mondial Change SA has no control over the data processing practices of such parties and accepts no responsibility for their content or applicable privacy policies. We encourage you to consult the privacy notices of any websites you visit directly.
2. Personal Data We Collect
The type of data we collect depends on the nature of our relationship with the Customer and on the regulatory obligations applicable to our activities as a financial intermediary.
Natural persons. During registration and throughout the contractual relationship, we collect: first and last name, email address, telephone number, nationality, type and number of identity document together with its expiry date, date of birth, full residential address, Swiss residence permit where applicable, declaration regarding Politically Exposed Person (PEP) status and US citizen or US person status, IBAN, and beneficiary bank.
Legal entities. For corporate customers, we also collect: company name, Commercial Register registration number, business sector, details of the authorised contact person, registered office, annual turnover, information regarding beneficial owners, and members of the management body. In both cases, completion of the KYC profile is carried out in accordance with the requirements of the PolyReg SRO Regulations.
Browsing data. For all website users, we collect technical information such as IP address, browser type, and device information. Further details are available in our Cookie Notice.
3. Purposes of Processing
We process personal data exclusively for specified, explicit, and legitimate purposes. In particular: to comply with the legal obligations applicable to us as a supervised financial intermediary (AMLA, FinIA, FinSA, PolyReg SRO Regulations, nFADP); to provide the Service and manage the contractual relationship with the Customer; to respond to requests from judicial or supervisory authorities where required by law; to conduct internal quality assurance activities, including the monitoring of communications; to send updates regarding new services, promotions, and operational information via email, SMS, WhatsApp, or push notifications, subject to prior consent where required.
4. Recipients of Personal Data
In connection with the provision of the Service, personal data may be disclosed—only to the extent strictly necessary and in compliance with applicable laws—to the following categories of recipients:
a) Authorised internal personnel. Access to the personal data of Swimo customers is restricted to a limited number of specifically authorised employees of Mondial Change SA, fewer than five at the date of this Privacy Notice, each acting within the scope of their operational responsibilities.
b) Authorities and supervisory bodies. Personal data may be disclosed to financial regulatory authorities, judicial authorities, accountants, and auditors where required or permitted by law.
c) Potential purchasers of the Company. In the event of a transfer of ownership or acquisition of control of Mondial Change SA, the acquiring entity will assume ownership of the personal data collected, together with the related rights and obligations, in accordance with this Privacy Notice.
d) Technical and marketing service providers. We work with selected service providers for the delivery of technical functionality and promotional activities. The complete list is provided below, together with links to their respective privacy policies:
| Function | Purpose | Service | Provider | Privacy Notice |
| vIBAN – Technical clearing infrastructure | Receipt of bank transfers relating to currency exchange transactions | vIBAN | Bivial AG (FINMA regulated)* | Privacy Notice |
| Customer messaging | Operational support and other communications | WhatsApp Business | Meta Platforms Ireland Ltd. | Privacy Notice |
| Tag management and traffic measurement | Centralised management of tracking tags and analysis of website user behaviour | Google Tag Manager / Google Analytics | Google LLC | Privacy Notice |
| Digital advertising campaigns | Delivery and measurement of advertising across the Google network | Google Ads | Google LLC | Privacy Notice |
| Social media advertising and retargeting | Delivery of advertisements and conversion tracking on Facebook and Instagram | Meta Ads (Facebook / Instagram) | Meta Platforms Ireland Ltd. | Privacy Notice |
| LinkedIn advertising campaigns | Monitoring traffic originating from LinkedIn and management of B2B campaigns | LinkedIn Insight Tag | Microsoft / LinkedIn Ireland | Privacy Notice |
| Transactional emails and direct marketing | Automated sending of operational notifications (transaction confirmation, exchange rate expiry) and promotional communications, etc. | Brevo | Sendinblue SA | Privacy Notice |
*Bivial AG acts exclusively as a technical sub-processor and infrastructure provider for Mondial Change SA; end users have no direct commercial, contractual, or custody relationship with Bivial AG.
5. Data Security
We implement technical and organisational measures appropriate to the risks associated with the processing of personal data. These include protected authentication through user credentials, encryption of data both in transit and at rest, firewalls and antivirus systems, anomaly monitoring, and granular access controls for authorised personnel. Data is stored on server infrastructure located within Europe.
6. Data Retention
Data relating to currency exchange transactions and KYC/AML documentation is retained for 10 years following the end of the contractual relationship, in accordance with the Swiss Anti-Money Laundering Act (AMLA), unless longer retention periods are required by specific legal provisions. Data processed for marketing purposes is retained until consent is withdrawn. At the end of each applicable retention period, the data is securely deleted or permanently anonymised.
7. Your Rights
As a data subject, you have the right to exercise the following rights at any time with respect to Mondial Change SA:
- Access: obtain confirmation as to whether your personal data is being processed and receive a copy of such data
- Rectification: request the correction of inaccurate personal data or the completion of incomplete data
- Erasure: request the deletion of personal data, subject to applicable legal retention obligations
- Restriction: request the restriction of processing where the legal requirements are met
- Objection: object at any time to the processing of your personal data for direct marketing purposes
- Data portability: receive your personal data in a structured, commonly used, and machine-readable format (where applicable under the GDPR)
- Withdrawal of consent: withdraw your consent for processing activities that require it, without affecting the lawfulness of processing carried out before such withdrawal
Withdrawal of consent or objection to processing may, in certain circumstances, prevent us from continuing to provide the Service.
To exercise your rights or for any questions regarding this Privacy Notice, please contact us at info@swimo.swiss. We will respond within 30 days.
You also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) if you reside in Switzerland, or with the Italian Data Protection Authority if you reside in Italy.
8. Data Controller and Data Protection Contact
The data controller for the personal data collected through swimo.swiss is:
| Corporate name | Mondial Change SA |
| Brand | Swimo (swimo.swiss) |
| Registered office | Via delle Scuole 2, 6900 Lugano, Switzerland |
| Registration number | CHE-113.900.267 |
| AML Supervisory Organisation | PolyReg SRO |
| info@swimo.swiss | |
| Telephone | +41 91 971 50 40 |
The person responsible for data processing is:
| Name | Rosario Forgione |
| info@mondial-change.ch | |
| Telephone | +41 91 971 50 40 |
Last updated: June 2026
