Effective date: 7 May, 2026

Swing & Shuffle (“we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how Swing & Shuffle handles your personal data when you join our waitlist or visit our website. It is written to comply with the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and the UK GDPR.

Because the platform is not yet operational, this policy currently covers only waitlist signups and website visits. We will publish a fuller Privacy Policy when the platform launches, and you will be notified before any expanded processing begins.

1. Who we are (the data controller)

The data controller responsible for your personal data is:

• Legal name: CJ Creative Studio, LLC. 

• Registered address: 215 Avenue B, #4A, New York, NY 10009

• Country of incorporation: United States

• Contact email: hello@swingandshuffle.com

2. Our representative in the European Union

As a controller established outside the EU offering services to people in the EU, we have appointed an EU representative under Article 27 of the GDPR. EU residents may contact our representative directly on any matter related to their personal data:

• Representative: Dimitar Anastasov

• Address: Cherkovna 35, Sofia, Bulgaria, Sofia

• Contact: mr.anastasov@gmail.com, +359 886991731

UK residents: where required by Article 27 of the UK GDPR, we have appointed a UK representative: Dimitar Anastasov, mr.anastasov@gmail.com, +359 886991731

3. What personal data we collect

Information you give us when joining the waitlist:

• First name and last name

• Email address

• City of residence

• Dance styles you practise (free text)

• Your indicated interest in being a host, a guest, or both

• Confirmation that you have agreed to these terms

Information collected automatically when you visit our website:

• IP address and approximate location derived from it

• Browser type and version, device type, operating system

• Pages visited, time of visit, referring URL

• Cookie identifiers (only with your consent for non-essential cookies — see Section 9)

We do not knowingly collect special category data (data revealing racial or ethnic origin, political opinions, religious beliefs, health data, sexual orientation, etc.) at the waitlist stage. Please do not submit such information through the waitlist form.

4. Why we use your data and our legal basis

Adding you to the waitlist and sending you launch updates

• Legal basis: Your consent (Art. 6(1)(a))

• Replying to questions you send us

  • Legal basis: Our legitimate interest in operating the waitlist (Art. 6(1)(f))

• Understanding how visitors use our website (analytics)

  • Legal basis: Your consent for non-essential cookies (Art. 6(1)(a))

• Keeping our website running and secure

  • Legal basis: Our legitimate interest in operating a secure service (Art. 6(1)(f))

• Complying with legal obligations

  • Legal basis: Legal obligation (Art. 6(1)(c))

You can withdraw your consent at any time by clicking the unsubscribe link in any email we send, by adjusting your cookie preferences, or by contacting us. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

5. Who we share your data with

We share personal data only with the following categories of recipients, and only to the extent necessary for the purposes described above:

• Email service provider (e.g., Resend, Postmark)

  • Purpose: Sending you emails about the waitlist

  • Location: [USA / EU]

• Website hosting provider (e.g., Vercel)

  • Purpose: Serving our website

  • Location: [USA / EU]

• Analytics provider (e.g., Plausible, GA4 — only if used and consented to)

  • Purpose: Understanding website usage

  • Location: [country]

• Database / data storage provider (e.g., Supabase, Airtable)

  • Purpose: Storing waitlist signups

  • Location: [country]

• Legal, accounting, and professional advisors

  • Purpose: Compliance and legal advice

  • Location: Various

We do not sell your personal data, and we do not share it with advertisers.

6. International data transfers

Because we are incorporated in the United States, your personal data is transferred to the United States when stored or processed by us. Some of our service providers may also process data outside the European Economic Area.

For transfers from the EEA, the UK, or Switzerland to the United States or to other countries that do not benefit from a European Commission adequacy decision, we rely on the following safeguards under Chapter V of the GDPR:

• Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914) signed with each relevant service provider.

• Where applicable, certification under the EU–US Data Privacy Framework for transfers to certified U.S. recipients.

• Supplementary technical and organisational measures, such as encryption in transit and at rest.

You may request a copy of the relevant safeguards by contacting us at hello@swingandshuffle.com 

7. How long we keep your data

We retain your waitlist data only for as long as we need it for the purposes described in this policy:

• Waitlist signup data: until 12 months after the platform launches publicly, until you unsubscribe, or until we abandon the project — whichever occurs first.

• Email correspondence: up to 24 months after the last interaction.

• Website logs and analytics: up to 14 months for analytics; up to 12 months for security logs.

• Records required by law (e.g., proof of consent, accounting records): for as long as required by applicable law.

If you unsubscribe from the waitlist, we will delete or anonymise your contact details promptly, retaining only the minimum necessary to demonstrate compliance with applicable law.

8. Your rights

If the GDPR or UK GDPR applies to you, you have the following rights regarding your personal data. You can exercise any of these rights free of charge by emailing hello@swingandshuffle.com or by contacting our EU representative (Section 2).

• Right of access (Art. 15) — to obtain a copy of the personal data we hold about you.

• Right to rectification (Art. 16) — to correct inaccurate or incomplete data.

• Right to erasure (Art. 17) — to ask us to delete your data, subject to legal exceptions.

• Right to restriction (Art. 18) — to ask us to limit how we use your data.

• Right to data portability (Art. 20) — to receive your data in a structured, commonly used, machine-readable format.

• Right to object (Art. 21) — to object to processing based on our legitimate interests.

• Right to withdraw consent (Art. 7(3)) — at any time, without affecting prior lawful processing.

• Right not to be subject to automated decision-making (Art. 22) — we do not currently make decisions affecting you using automated processing.

We will respond to verified requests within one month. In complex cases, this period may be extended by up to two further months, in which case we will tell you why.

Right to lodge a complaint. If you believe we have not handled your personal data properly, you have the right to lodge a complaint with a data protection authority. EU residents can complain to the supervisory authority of their country of residence. UK residents can complain to the Information Commissioner's Office (ico.org.uk). We would, however, appreciate the chance to address your concerns first.

9. Cookies and similar technologies

We use a small number of cookies to make our website work, to remember your cookie preferences, and (only with your consent) to understand how visitors use the site.

Strictly necessary cookies:

These cookies are essential for the website to function. They store your cookie preferences and protect against abuse. They do not require consent under the ePrivacy Directive.

Analytics cookies (only if you consent):

If you consent, we may use analytics cookies ([e.g., Plausible / Google Analytics 4]) to understand which pages are popular and how visitors find us. You can change your preferences at any time using the "Cookie settings" link in the footer.

We do not use advertising cookies or cross-site tracking cookies.

10. Children

Our waitlist is intended for people aged 18 and over. We do not knowingly collect personal data from children. If you believe a child has submitted information to us, please contact us at hello@swingandshuffle.com and we will delete it.

11. Security

We use reasonable technical and organisational measures to protect personal data, including encryption in transit (TLS), restricted access to systems, and selection of service providers that maintain industry-standard security practices. No system is perfectly secure, and we cannot guarantee that personal data will never be exposed to a security incident. If a personal data breach occurs that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay, as required by Article 34 GDPR.

12. Changes to this policy

We may update this Privacy Policy from time to time. If we make material changes — for example, when the platform launches and we begin processing additional categories of data — we will notify waitlist members by email before the changes take effect, and update the "Last updated" date at the top of this page.

13. Contact

For any questions about this Privacy Policy or your personal data, please contact:

• Email: hello@swingandshuffle.com

• Postal address: 215 Avenue B, #4A, New York, NY 10009

• EU representative: Dimitar Anastasov (see Section 2)