Elder Swamp Club Privacy Policy

Last updated: July 30, 2026

Elder Swamp Club, Inc. a/k/a Swamp Club ("Swamp Club," "we", “us” or "our") develops “Swamp,” a deterministic automation framework that enables AI agents and their users to build, execute, and share repeatable workflows, and operates “Swamp Club,” the associated community platform. This Privacy Policy describes how Swamp Club processes personal information that we collect through our digital and online properties or services that link to this Privacy Policy (including as applicable, our website, web application, member platform, electronic communications, and social media pages) as well as our marketing activities, and other activities described in this Privacy Policy (collectively, the “Service”).

European Users: Please see the ‘Notice to European Users’ section below for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe,” and “European” should be understood accordingly).

Personal information we collect

Information you provide to us. Personal information you may provide to us includes:

Contact data, such as your first and last name, alias, salutation, email address, billing and mailing addresses, phone number, professional title, and company name.
Profile data, such as account name, the username and password that you may set to establish an online account on the Service, biographical details, job title, avatar, photograph or picture, date of birth, interests, preferences, links to your profiles on social media networks, participation data such as points, ranks, badges, and activity streaks associated with your Swamp Club profile and any other information that you add to your account profile.
Payment data needed to complete transactions, including payment card information or bank account number. We use a third-party vendor to directly collect and process your payment card information, as described further below.
Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via email, phone, chat features, social media, or otherwise.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Data about others. We may offer features that help users invite their contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

Third-party sources. We may combine personal information we receive from you with personal information of the kinds identified above that we obtain from other sources, such as:

Service providers that provide services on our behalf or help us operate the Service or our business.
Data analytics providers
Social media and developer platforms
AI agents that you may choose to connect to Swamp.

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Location data, which is approximate and inferred from your IP address and network data.
Communication interaction data such as your interactions with our email, text, comments on Lab issues, Discord, or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails enabling us to detect if you have opened or forwarded a message.
Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Telemetry and usage data, collected when you use Swamp or Swamp-club.com, including the commands you run, the outcome of these commands, execution duration and timestamps, operating system, deno version, Swamp version, and the AI agent detected or configured in your session.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

provide and operate the Service;
enable security features of the Service;
personalize the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
establish and maintain your user profile on the Service;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, user-to-user communications, and support and administrative messages;
understand your needs and interests, and personalize your experience with the Service and our communications;
provide support for the Service, and respond to your requests, questions and feedback;
facilitate team collaboration features, including enabling you to create and share workflows and extensions with your team;
facilitate community features of the Service, including the Swamp Club leaderboard, rankings, badges, and activity tracking;
collect and share user testimonials; and
fraud prevention and security.

Research and development. We may use your personal information for research and development purposes, including to develop, analyze and improve our platform and the Swamp Club community. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information. We may use this anonymous or de-identified data and share it with third parties for any lawful business purposes. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Marketing. We may collect and use your personal information for direct marketing purposes. For example, we may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section.

Data sharing in the context of corporate events. We may share certain personal information in the context of actual or prospective corporate events – for more information, see ‘How we share your personal information’, below.

Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, court orders, investigations or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use, or share your personal information for further purposes, if those purposes are not compatible with the initial purpose for which that personal information was collected.

Data sharing in the context of corporate transactions, we may share certain personal information in the context of actual or prospective corporate transactions – for more information, see How we share your personal information, below.

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates. In some cases, our corporate parent, subsidiaries, and affiliates might have access to personal information.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, internet service providers, information technology, customer support , email delivery, marketing, consumer research and website/data analytics).

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, available at https://stripe.com/privacy.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account on the third-party service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties in litigation, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Corporate transactions. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Elder Swamp Club, financing of Elder Swamp Club, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your personal information to an acquirer, successor, or assignee of Elder Swamp Club or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Other users and the public. Your Profile data may be visible to other users of the Service, on our Discord server, and the public. For example, your leaderboard profile, including your username, rank, points, badges, and activity streak may be visible to other users. Extensions, Workflows, Models, and other files you choose to share, published to the extension registry may also be accessible to other users. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information. Once you publish content, it may be copied and stored on third party systems where you might not have the ability to have it deleted.

Your choices

In this section, we describe the choices available to you.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and navigating to your account profile and settings.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. It may take time for your opt-out to be effective. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. You may opt-out of text messages by texting “STOP” in response to a text that you receive or by other reasonable means.

Cookies. We ask before setting any non-essential cookie or browser storage: a consent banner offers Decline, Customize, and Accept as equal choices, and analytics or advertising storage exists only after you grant the corresponding purpose. You can review or withdraw your answer at any time via the "Cookie Settings" link in the site footer, and our Cookie Policy lists every cookie and storage key we use, what it does, and how long it lives. Independently of that, most browsers let you remove or reject cookies through your browser settings; note that disabling all cookies may keep parts of the Service (such as signing in) from working properly. For general information about cookies, visit http://www.allaboutcookies.org .

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading, so the business hosting the image will not detect that you have viewed a page. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. Swamp Club is designed to be used in conjunction with third-party AI agents you choose, such as Claude, Cursor, Copilot, Codex, and others. We are not responsible for how your AI provider collects, uses, or shares your information. Your use of third-party AI tools are governed by your agreements with the provider of such tools. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all Internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users in Europe should read the information provided below about the transfer of personal information to recipients outside of Europe.

Children and Teens

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a minor from whom you believe we have collected personal information in a manner prohibited by law, or if information was provided on your behalf when you were under 18, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

The "LAST UPDATED" legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. We reserve the right to modify this Privacy Policy at any time. We will notify you by updating the “Last Updated” date. Depending on the kind of change we make, we may also notify you directly or ask for your consent to the change. Any modifications to this Privacy Policy will be effective upon our posting the modified version or as otherwise indicated at the time of posting.

How to contact us

Email: support@swamp-club.com
Website: https://swamp-club.com

Notice to European users

General

Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”)) and the EU GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”)). Under the GDPR, “personal data” means information about individuals from they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in the section “Personal Information we collect” that is set out above.

Controller. Elder Swamp Club is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to contact us’ section above for our contact details.

Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:

Our Representative in the EU. Our EU representative appointed under the EU GDPR is European Data Protection Office (EDPO). You can contact them: By email to: https://edpo.com/gdpr-data-request/ By postal mail to: EDPO, Avenue Huart Hamoir 71, 1030 Brussels, Belgium	Our Representative in the UK. Our UK representative appointed under the UK GDPR is EDPO UK Ltd. You can contact them: By email to: https://edpo.com/uk-gdpr-data-request/ By postal mail to: EDPO UK Ltd, Unit 33, Waterside, Schooner Court, 44-48 Wharf Road, London, N1 7UX, United Kingdom

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

Where we need to process your personal information in order to deliver the Service to you, or where you have asked us to take specific action which requires us to process your personal information (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see the ‘How we use your personal information’ section above and the description of associated data sharing relevant to such purposes set out in the ‘How we share your personal information’ section also above.

Purpose	Categories of personal information involved	Legal basis
Service delivery and operations	Contact data Profile Data Communications data Payment data Data from Third Party Services Device data Telemetry and usage data	Contractual Necessity Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service (including, where relevant, responding to any contact via any “contact us” feature or similar), our business and associated IT services, systems and networks
Research and development	Any and all data types relevant in the circumstances	Legitimate interest. We have a legitimate interest in providing you with a good service and analysing how you use it so that we can improve it over time, as well as developing and growing our business. We also have legitimate interest in taking steps to preserve the privacy of our users. Consent, in respect of any optional cookies used for this purpose.
Direct marketing	Contact data Profile data Communications data Marketing data Communication interaction data	Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Compliance and protection	Any and all data types relevant in the circumstances	Compliance with Law. Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
Data sharing in the context of corporate transactions	Any and all data types relevant in the circumstances	Legitimate Interests. We have a legitimate interest in providing information to relevant third parties who are involved in an actual or prospective corporate event (including to enable them to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations).
Further uses	Any and all data types relevant in the circumstances	The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or otherwise for the ‘Compliance and protection’ purposes outlined above.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information that we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other information

No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. We will notify you if this is the case at the time.

No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, information related to sex life or sexual orientation, trade union membership, or information pertaining to criminal convictions) on or through the services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

Your rights

General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information which you have provided to us.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights. You may submit these requests by email to support@swamp-club.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://www.edpb.europa.eu/about-edpb/our-members_en
For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe

We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.
Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S.).
- However, in these cases:
  - we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorise for this purpose; or
  - in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at support@swamp-club.com.