Privacy Policy

Last updated: June 20, 2026

Shaanxi Sujia Network Technology Co., Ltd., operating as Swift Grace (referred to as the Company, we, us, or our), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website swiftgrace.surf (the Site) or engage with our services. By accessing or using the Site, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with any part of this policy, you must discontinue use of the Site immediately.

1. Information We Collect

1.1 Personal Information You Provide

We collect personal information that you voluntarily provide when you interact with our Site or communicate with us. This includes but is not limited to: your full name, email address, phone number, company or organization name, job title, physical address, and any other information you choose to include in inquiries, contact form submissions, project briefs, or other communications directed to us. When you submit our contact form, we collect the data you enter along with metadata including the timestamp of submission and your IP address for spam prevention and security purposes.

1.2 Information Collected Automatically

When you access the Site, certain information is automatically collected by our servers and third-party service providers. This includes your Internet Protocol (IP) address, browser type and version, operating system, device type, screen resolution, referring URL, pages visited, date and time of visit, time spent on pages, clickstream data, and other diagnostic data. We use this information for Site analytics, performance monitoring, security threat detection, and to improve the user experience. This information is collected through server logs, cookies, and similar tracking technologies as described in Section 5 of this policy.

1.3 Information from Third Parties

We may receive information about you from third-party sources, including analytics providers such as Google Analytics, advertising networks, and business partners. This information may be combined with the information you provide directly to us. We take reasonable steps to ensure that any third-party data sources we use have obtained your consent or otherwise have a lawful basis for sharing your information with us.

2. How We Use Your Information

2.1 Primary Uses

We use the personal information we collect for the following purposes: to respond to your inquiries and provide customer support; to evaluate, develop, and deliver our computer systems design, network engineering, and technology consulting services; to send you administrative communications including confirmations, invoices, technical notices, and security alerts; to send you marketing and promotional communications where you have provided explicit consent; to process transactions and manage our contractual relationships; to improve, personalize, and expand our Site and services; to monitor and analyze Site usage, trends, and activities; to detect, prevent, and address technical issues, fraud, and security incidents; and to comply with legal obligations and enforce our Terms of Service.

2.2 Legal Basis for Processing (GDPR)

If you are a resident of the European Economic Area (EEA) or the United Kingdom, our legal basis for collecting and using your personal information depends on the specific context. We process your personal data based on: your explicit consent, which you may withdraw at any time; the performance of a contract with you; our legitimate business interests, provided those interests are not overridden by your data protection rights; compliance with a legal obligation; and/or protection of your vital interests or those of another person.

2.3 Data Minimization

We adhere to the principle of data minimization. We collect and process only the personal information that is necessary for the specific purposes outlined in this policy. When your personal information is no longer required for the purpose for which it was collected, we securely delete or anonymize it in accordance with our data retention schedule.

3. Data Sharing and Disclosure

3.1 Service Providers

We may share your information with trusted third-party service providers who perform functions on our behalf. These include but are not limited to: hosting and infrastructure providers (such as cloud storage and computing services), analytics providers (such as Google Analytics), email communication platforms, customer relationship management tools, payment processors, and security monitoring services. Each service provider is carefully vetted and is contractually obligated to process your data only on our documented instructions, to maintain appropriate security measures, and to comply with applicable data protection laws.

3.2 Legal Requirements

We may disclose your personal information if required to do so by law or in response to valid legal process, including subpoenas, court orders, warrants, or equivalent legal instruments issued by competent authorities. We may also disclose your information to: comply with applicable laws, regulations, or governmental requests; protect the rights, property, or safety of the Company, our clients, or the public; detect, prevent, or otherwise address fraud, security, or technical issues; and enforce our contractual rights and Terms of Service.

3.3 Business Transfers

In the event of a merger, acquisition, restructuring, reorganization, dissolution, or sale of all or a portion of our assets, your personal information may be among the assets transferred to the successor entity. You will be notified via email and/or a prominent notice on our Site of any such change in ownership or control of your personal data, as well as any choices you may have regarding your information.

3.4 No Sale of Personal Data

We do not sell, rent, trade, or otherwise disclose your personal information to third parties for their direct marketing purposes. We do not monetize your personal data through sale to data brokers or advertising networks. Any sharing of information is strictly limited to the purposes described in this policy.

4. International Data Transfers

Your information may be transferred to and processed in countries other than the country in which you reside. Our servers and primary operations are located in China. If you access our Site or services from outside China, your data will be transferred to and processed in China and potentially other jurisdictions where our service providers operate. These jurisdictions may have data protection laws that differ from those in your country of residence. We take appropriate safeguards to ensure that any international transfer of your personal data complies with applicable law and that your information remains protected, including through the use of standard contractual clauses approved by relevant regulatory authorities, binding corporate rules, or other lawful transfer mechanisms.

5. Cookies and Tracking Technologies

5.1 Essential Cookies

Our Site uses essential cookies and similar technologies that are strictly necessary for the operation of the Site. These include session cookies that maintain your browsing state, security cookies that help prevent cross-site request forgery attacks, and load-balancing cookies that ensure reliable delivery of Site content. These cookies do not require your consent under applicable data protection laws because they are essential for the Site to function.

5.2 Analytics Cookies

We use analytics cookies, including those provided by Google Analytics, to collect information about how visitors use our Site. These cookies help us understand which pages are most frequently visited, how users navigate through the Site, and whether users encounter errors. The information collected by these cookies is aggregated and anonymized. We use this data to improve Site performance, content relevance, and user experience. Google Analytics processes data in accordance with its own privacy policy. You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on available at tools.google.com/dlpage/gaoptout.

5.3 Cookie Management

Most web browsers allow you to control cookies through their settings. You can configure your browser to refuse all cookies, delete existing cookies, or alert you when cookies are being set. Please note that disabling cookies may affect the functionality of the Site and limit your ability to use certain features. For more information about managing cookies, visit the help documentation for your specific browser or refer to resources provided by organizations such as allaboutcookies.org.

6. Data Security

We implement and maintain appropriate technical and organizational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include: encryption of data in transit using Transport Layer Security (TLS) protocols; encryption of data at rest where technically feasible; network firewalls and intrusion detection systems; regular security assessments and vulnerability scanning; role-based access controls and the principle of least privilege; secure software development practices including code reviews and dependency audits; employee training on data protection and security procedures; and incident response procedures to address potential data breaches. However, no method of electronic transmission or storage is 100 percent secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

7. Data Retention

We retain your personal information only for as long as is necessary to fulfill the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements. The specific retention period depends on the nature of the data and the purpose for which it was collected: Contact form submissions and related correspondence are retained for up to 3 years after your most recent interaction with us; contractual and transaction records are retained for the duration of the contract plus 7 years to comply with tax and commercial record-keeping obligations; technical and security logs are retained for 12 months; marketing consent records are retained indefinitely unless you withdraw consent. When personal information reaches the end of its retention period, it is securely deleted, destroyed, or anonymized in accordance with our data disposal procedures.

8. Your Rights

8.1 Access, Correction, and Deletion

Depending on your jurisdiction, you may have the following rights regarding your personal information: the right to access and obtain a copy of the personal data we hold about you; the right to request correction of inaccurate or incomplete personal data; the right to request deletion of your personal data (the right to be forgotten); the right to restrict or object to the processing of your personal data under certain circumstances; the right to data portability, allowing you to receive your data in a structured, commonly used, and machine-readable format; and the right to withdraw consent at any time where processing is based on your consent. To exercise any of these rights, please contact us using the information provided in Section 12. We will respond to all legitimate requests within 30 calendar days. We may ask you to verify your identity before responding to your request.

8.2 Rights Under the CCPA

If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) grant you additional rights. These include the right to know what personal information we collect, use, disclose, and sell; the right to request deletion of your personal information; the right to opt out of the sale or sharing of your personal information; the right to correct inaccurate personal information; and the right to non-discrimination for exercising your privacy rights. We do not sell or share personal information as defined under California law. To exercise your rights under California law, contact us using the information in Section 12. You may designate an authorized agent to submit requests on your behalf.

8.3 Rights Under the PIPL

If you are located in the People's Republic of China, the Personal Information Protection Law (PIPL) grants you specific rights regarding your personal data. These include the right to know and to decide concerning the processing of your personal information; the right to access, copy, correct, and delete your personal information; the right to request the transfer of your personal information to another processor; and the right to restrict or refuse the processing of your personal information. We process personal information in accordance with PIPL, including obtaining separate consent where required for sensitive personal information, conducting personal information protection impact assessments for high-risk processing activities, and designating a person responsible for personal information protection.

8.4 Complaint Rights

If you believe that our processing of your personal data violates applicable data protection law, you have the right to lodge a complaint with the supervisory authority in your country of residence, your place of work, or the place of the alleged infringement. We encourage you to contact us first so that we can address your concerns directly.

9. Children's Privacy

Our Site and services are not directed to individuals under the age of 16, and we do not knowingly collect personal information from children. If we become aware that a child under the age of 16 has provided us with personal information without verifiable parental consent, we will take prompt steps to delete such information from our systems. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately using the details in Section 12.

10. Third-Party Links and Services

Our Site may contain links to third-party websites, plugins, and services that are not owned or controlled by us. This Privacy Policy does not apply to the practices of those third parties. We are not responsible for the content, privacy practices, or security of any third-party websites or services. We encourage you to review the privacy policies of each third-party service you interact with before providing any personal information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or operational needs. When we make changes, we will revise the last updated date at the top of this policy and post the updated version on this page. For material changes that significantly affect your rights or the way we process your personal data, we will provide additional notice, which may include sending you an email notification, displaying a prominent notice on the Site, or requesting your renewed consent where required by law. We encourage you to review this Privacy Policy periodically to stay informed about our privacy practices. Your continued use of the Site after any modifications to this Privacy Policy constitutes your acceptance of the updated terms.

12. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data processing practices, or if you wish to exercise any of your data protection rights, please contact us using the information below. We are committed to addressing all inquiries promptly and transparently.

Shaanxi Sujia Network Technology Co., Ltd.
No. 5-200026501, 37 Yongfeng Village
Yongle Town, Jinghe New City
Xihou New District, Xi’an, Shaanxi 710000
China

Email: team@swiftgrace.surf
Phone: +15808965955