Legal Notice

1. Company Details

Company Name: Swapli by Webguy BV Registration Number (KVK): 72381647 Tax Identification Number (BTW): NL859193621B01 Registered Address: Rokin Business Center, Rokin 92, 1012 KZ Amsterdam, The Netherlands Jurisdiction of Incorporation: Netherlands

Website: https://swapli.net General Email: info@swapli.net Legal Email: legal@swapli.net

2. Legal Representative

Director (Bestuurder): Daniel Email: daniel@webguy.co.il

3. Data Protection Officer (DPO)

Name: Daniel Email: dpo@swapli.net

In accordance with Articles 37-39 of the GDPR, the Data Protection Officer is responsible for monitoring Swapli's compliance with data protection requirements and for handling inquiries and requests concerning the rights of data subjects.

4. Supervisory Authority

Dutch Data Protection Authority: Autoriteit Persoonsgegevens (AP) Bezuidenhoutseweg 30 2594 AV Den Haag, Netherlands Website: https://www.autoriteitpersoonsgegevens.nl Telephone: +31 (0)70 888 8500

5. Nature of Service

Swapli is an online matchmaking platform connecting Israeli families worldwide for the purpose of home exchanges. Swapli is not a party to the exchanges themselves and does not bear responsibility for the outcomes of such exchanges. See the Terms of Service for full details.

Classification under the Digital Services Act (DSA): Swapli is classified as an "intermediary service" and "hosting service" in accordance with Regulation (EU) 2022/2065, Articles 4-6.

6. Digital Services Act — Obligations

In accordance with Regulation (EU) 2022/2065, Swapli maintains the following obligations:

6.1 Point of Contact (Article 12)

Point of contact for communication with authorities, users, and the European Commission:

Email: legal@swapli.net Languages: Hebrew, English, Dutch

6.2 Reporting Illegal Content (Article 16)

Users may report illegal or infringing content through:

"Report" Button — Available on every profile, property, message, and image on the platform.
Email: report@swapli.net

Every report will be processed without undue delay, and a reasoned notice will be provided to both the reporter and the user whose content was reported.

6.3 Appeal Mechanism (Article 20)

A user whose content has been removed or whose account has been restricted may appeal the decision:

Via Platform: "Appeal" button in the restriction notice.
Via Email: legal@swapli.net

The appeal will be reviewed by a human (not an automated system) and a reasoned response will be provided within 14 business days.

6.4 Transparency (Article 15)

Swapli publishes an annual transparency report containing:

Number of reports received and their outcomes
Number of appeals received and their outcomes
Number of user restrictions imposed and their justifications
Number of law enforcement requests

The report will be published at: swapli.net/legal/transparency-report

6.5 Terms and Restrictions (Article 14)

Swapli's Terms of Service, including moderation policy, are available at: swapli.net/legal/terms-of-service

The Terms of Service are written in clear and accessible language and specify:

Types of prohibited content
Moderation and enforcement tools used
Users' appeal rights

7. Hosting and Intermediary — Limitation of Liability (DSA Articles 4-6)

Swapli operates as a hosting service in accordance with DSA Article 6. This means:

Swapli is not liable for information uploaded by users to the platform, provided Swapli is not aware that the information is illegal.
Upon receiving notice of illegal content, Swapli acts without undue delay to remove or block access to such content.
Swapli is not obligated to proactively monitor all content uploaded by users (DSA Article 8).

8. Online Dispute Resolution (ODR)

In accordance with Regulation (EU) 524/2013, the European Commission operates a platform for online dispute resolution:

ODR Platform Link: https://ec.europa.eu/consumers/odr

Swapli is not obligated to participate in alternative dispute resolution (ADR) proceedings unless otherwise required by law.

9. Consumer Right of Withdrawal

In accordance with the EU Consumer Rights Directive (2011/83/EU), consumers in the European Union have a right of withdrawal of 14 days from the date of purchase of a subscription, without need for justification.

To withdraw: Contact support@swapli.net or use the withdrawal form in your account settings.

Full details are available in the Terms of Service, Section 4.

10. Intellectual Property

All content, design, logos, code, and trademarks on swapli.net are owned by Webguy BV or its licensors and are protected by international copyright laws and European Union law.

No content may be copied, distributed, modified, or used for commercial purposes without prior written consent.

Photos of properties and content uploaded by users remain their property, subject to the limited license specified in the Terms of Service (Section 10).

11. Limitation of Liability

Swapli provides the platform "as is". Subject to applicable law:

Swapli is not liable for direct or indirect damages arising from the use of the platform.
Swapli is not liable for content uploaded by users, user behavior, or the outcomes of home exchanges.
Swapli's total liability is limited to the amount of membership fees paid in the previous 12 months.

This limitation does not apply to damages caused by willful misconduct or gross negligence, in accordance with Dutch law.

12. Governing Law and Jurisdiction

Governing Law: Laws of the Netherlands Jurisdiction: Competent court in Amsterdam, Netherlands

The choice of Dutch law does not deprive consumers in the European Union of the protections afforded to them by the laws of their country of residence, insofar as such protections cannot be waived by agreement.

13. Prevailing Language

This legal notice is available in Hebrew and English. In the event of any discrepancy, the Hebrew version shall prevail.

14. Additional Legal Documents

Terms of Service: swapli.net/legal/terms-of-service
Privacy Policy: swapli.net/legal/privacy-policy
Cookie Policy: swapli.net/legal/cookie-policy
Code of Conduct: swapli.net/legal/code-of-conduct
Transparency Report: swapli.net/legal/transparency-report (to be published after the first year)

15. Contact Information

General Questions: info@swapli.net
Legal Questions: legal@swapli.net
Privacy & GDPR: privacy@swapli.net
Data Protection Officer: dpo@swapli.net
Content Report: report@swapli.net
Security: security@swapli.net
Support: support@swapli.net

Swapli by Webguy BV Rokin Business Center, Rokin 92, 1012 KZ Amsterdam, The Netherlands Registration Number: KVK (COC) 72381647