Privacy Policy

Swiggle Privacy Policy

Last Modified: November 19, 2016

Introduction:

The founders of Swiggle Inc. respect and cherish privacy.  When we built Swiggle, we strived to create a service that would meet the strong privacy expectations and standards of our users.

WE WILL NOT USE OR SHARE YOUR INFORMATION WITH ANYONE EXCEPT AS DESCRIBED IN THIS PRIVACY POLICY.

By using our Service, you agree to our Terms of Service and consent to the collection, use and disclosure of your personal information and other activities as described in this Privacy Policy.

Background:

This Privacy Policy is an integral part of our Terms of Service and describes how we collect and use Personal Information.  You can find our complete Terms of Service at http://swiggle.co/mobile-terms-of-service/).

This Privacy Policy applies to your use of any Service location (e.g., website or mobile app) that posts a link to this Privacy Policy and all features, content, and other services that we own, control, and make available through such service location. It does not apply to our data collection activities offline or outside of our Service (unless otherwise stated below or at the time of collection).

1. Scope — Privacy Policy, Terms of Service, Third Party Links and Aggregated Data

1.1. Privacy Policy.

This Privacy Policy (this “Privacy Policy”) applies to information we collect or use on websites, including, www.swiggle.co, mobile applications, products, features, services, or any portion thereof (collectively, the “Service”), owned or controlled by Swiggle Inc., a federally incorporated Canadian corporation, or its affiliated companies (“Company” or “we” or “our” or “us”). Affiliated companies are entities that control, are controlled by or are under common control with the Company.

1.2. Terms of Service.

This Privacy Policy and the Company Terms of Service (“Terms of Service”), incorporated herein by reference, are an agreement (collectively, this “Agreement”) between Company and you (“You” or “your” or “you”), a user of the Service. By accessing or using the Service, you acknowledge and agree to this Privacy Policy and the Terms of Service. If you choose to not agree with the Privacy Policy or the Terms of Service, you may not use the Service.

1.3. Third Party Links to Other Websites or Services.

The Service contains third party links to other websites or services. Please be aware that we are not responsible for the content or privacy practices of such other third party websites or services. We encourage our users to be aware when they leave Company’s Service and to read the privacy statements of any other site that collects personal information.

1.4. Aggregated Data.

Personal information once “de-identified” and aggregated will not be subject to this Privacy Policy and we and our third parties may treat it as non-personal information and use it without obligation to you except as prohibited by applicable law.

2. Information Collection.

2.1. Information You Provide.

We may collect information that identifies you (“Personal Information”) when you use the Service or register for an account. The types of Personal Information that we may collect include:

2.1.1. When you register for an account by connecting to the Service through 3rd party email accounts (e.g. Gmail, Outlook), you may be allowing us access to your contact information such as your name, address, phone number, birth date, and email address;

2.1.2. Information that you provide to connect your email accounts to the Service or take action regarding claims;

2.1.3. Information that you provide to us, such as your name, location, address, phone number, and email address;

2.1.4. Information that you provide to us, such as credit card, debit card or bank information, for billing and for filing price protection claims with payment processors and credit card companies, using the payment information (e.g. card number, cvc, expiration, and billing address)

2.1.5. By using the Services, you may be allowing us to collect Information by filtering your email account for receipts, using your credentials and authorization, to determine items, products and services acquired by you and your purchase history.

2.1.6. Based on the settings of your device and should you specifically allow, you may be sharing with us your location.

2.1.7. If you are accessing our Services through an Apple device, Your device’s Apple Identifier for Advertisers (IDFA).

2.1.8. Information that you provide to us if you participate in a sweepstakes, contest, rewards program, or other promotion;

2.1.9. Information that you provide if you use the Service to upload, share, or communicate any content or information, including photos, images, videos, text, social network accounts, or other Personal Information that you may include about yourself or others;

2.1.10. Information that you publicly post via social media networks, forums, blogs, message boards, chat rooms or similar functionality is public information that we, or others, may share or use in accordance with the law;

2.1.11. Information that you provide if you email, phone, contact or communicate with us or our third party service providers, such as your email address or phone number.

2.2. Information We Collect.

2.2.1. Information from public databases and third parties;

2.2.2. We use a tool called “Google Analytics” to collect information about use of this Service, such as how often users visit the Service, what pages they visit when they do so, and what other sites they used prior to coming to the Service. As of the date this Privacy Policy was last updated, Google Analytics collects only the IP address assigned to you on the date you visit this Service, rather than your name or other identifying information.

2.2.3. Traffic and usage information generated from your visit to the Service, including traffic data, pages you visit, browser information, operating system, IP address, cookie information, and the type of device that you use to access the Service;

2.2.4. In connection with your visit or use of the Service, we may automatically collect information about our users, such as the numbers and frequency of users and their characteristics and information about similar groups of users, certain age groups or users that live in a particular geographical area. This data is only used in the aggregate as a statistical measure and not in a manner that would identify you personally. Aggregate information generally is collected through the use of cookies and beacons;

2.2.5. Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this Site. As of the date this Privacy Policy was last updated, this cookie cannot be used by anyone but Google, Inc. The information generated by the cookie will be transmitted to and stored by Google on its servers.

2.2.6. We use the information received from Google Analytics only to improve services on this Site. We do not combine the information collected through the use of Google Analytics with Personal Information.

2.2.7. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Privacy Policy (as it may be updated by Google from time to time). You can prevent Google Analytics from recognizing you on return visits to this Site by disabling the Google Analytics cookie on your browser.

2.3. Children Under The Age of 13.

We do not collect or solicit any information from anyone under the age of 13 or allow people under the age of 13 to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at support@swiggle.co.

3. Tracking Technologies We Use.

We may use one or more of the following tracking technologies, and similar future tracking technologies, to automatically collect information: cookies, local shared objects, web beacons, unique telephone numbers, general log information and referral information from third-party services.

3.1. “Cookies” are alphanumeric identifiers that we transfer to your computer’s hard drive through your Web browser to enable our systems to recognize your browser and tell us how and when pages in the Service are visited and by how many people. Our cookies do not collect personal information, and we do not combine information collected through cookies with other personal information to tell us who you are or your screen name or e-mail address. The “Help” portion of the toolbar on the majority of browsers will direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. We recommend that you leave the cookies activated because cookies allow you to use many features of the Service.

3.2. “Web beacons,” also known as an Internet tags, pixel tags or clear GIFs, link web pages to web servers and their cookies. Web beacons can be embedded in web pages, videos, or emails, to collect certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the content, the IP address of your computer, and the URL of the web page from which the content was viewed.

3.3. “Local shared objects,” sometimes known as Flash cookies, may be used to store your preferences or display content based upon what you have viewed on various websites to personalize your visit.

3.4. “Ad IDs” and Other In-App Tracking Methods. There are a variety of tracking technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs” to associate app user activity to a particular app.

4. How We Use Your Information.

We may use the information that we collect for any of the following purposes:

4.1. To provide, operate, maintain, improve, and promote the Service;

4.2. To enable you to access and use the Service, including uploading, downloading, collaborating and sharing content, photos, images, videos and information, with other users or third parties;

4.3. To process and complete transactions, and send you related information, including purchase confirmations and invoices;

4.4. To send transactional messages, including responding to your comments, questions, and requests; providing customer service and support; and sending you technical notices, updates, security alerts, and support and administrative messages;

4.5. To send promotional communications, such as providing you with information about services, features, newsletters, offers, promotions, contests, events and sending updates;

4.6. To monitor and analyze trends, usage, and activities in connection with the Service and for marketing, advertising, administrative, analytical, research, optimization, and other purposes. For example, we may use statistical analyses of usage data in order to measure interest in the various areas of the Service, for development purposes and to inform advertisers and partners in aggregate and anonymous terms about consumers who click on their advertising or other messages. IP addresses are also used for systems administration and troubleshooting purposes.

4.7. To investigate and prevent fraudulent transactions, unauthorized access to the Service, and other illegal activities;

4.8. To personalize the Service’s content, features or advertisements, including, without limitation, using purchase information from emails to provide you with relevant advertisements (e.g. accessories for a recent purchase);

4.9. Manage, on your behalf as your agent, your online account(s), including orders, receipts, claims, and returns;

4.10. Understand which areas and features of our Service are popular, understanding campaign effectiveness, tailoring our communications with you, and determining whether an email has been opened and links within the email have been clicked

4.11. Personalize Your online experience and provide advertisements, content or features that match Your profile and interests

4.12. Verify that your email address(es) and shopping account(s) are active and valid; and

4.13. Process your purchase history, initiate and facilitate claims on your behalf as your agent, and communicate with you and third parties about your claims.

5. Information Sharing.

5.1. Advertising Partners.

Ads appearing on the Service may be delivered to users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by the Service and does not cover the use of cookies by any advertisers, each of whom maintain their own privacy policy.

5.2. Service Providers.

We engage service providers to perform functions and provide services to us. We may share your private personal information with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions.

5.3. Payment Processors.

We share your payment information with payment services providers to:

5.3.1. Process payments;

5.3.2. Prevent, detect and investigate fraud or other prohibited activities;

5.3.3. Facilitate dispute resolution such as chargebacks or refunds;

5.3.4. For other purposes associated with the acceptance of credit or debit cards. We may share your credit or debit card number with payment services providers or card networks to monitor card transactions at participating merchants and track redemption activity for the purposes of providing card-linked services.

5.4. Authorized Personnel.

Our employees, agents, consultants, contractors, or other authorized personnel, may have access to user information as necessary in the normal course of our business.

5.5. Business Transfers.

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if the Service or Company, or substantially all of its assets, were acquired, liquidated, or dissolved, user information would be one of the assets that is transferred.

5.6. Government, Law Enforcement or Third Parties.

We may disclose any information, including, without limitation, Personal Information that we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. We also may exchange information, including, without limitation, Personal Information, with other companies and organizations to protect the rights, property, or safety of Company and its affiliates, personnel, users, third parties, or others. We reserve the right to disclose a user’s Personal Information if we believe, in good faith, that the user is in violation of the Terms of Service, even without a subpoena, warrant or other court order.

5.7. Social Media Networks.

We may include applications or widgets from social media networks that allow interaction or content sharing by their users. These widgets, such as a Facebook “Share” or “Like” button, are visible to you on the web page you visit. Integration between the Service and social media networks such as Facebook, Twitter and others may allow social media networks in which you participate to collect information about you, even when you do not explicitly activate the network’s application or widget. Please visit the applicable social media network’s privacy policy to better understand their data collection practices and choices they make available to you. The privacy policy of the social media network controls the collection, use and disclosure of all personal information transmitted to that network.

6. Choice and Opt-Out.

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information.

6.1. Choice.

In accordance with local law, your controls and choices may include:

6.1.1. You may correct, update and delete your account information, as described below;

6.1.2. You may change your choices for subscriptions and newsletters;

6.1.3. You may choose whether or not to receive offers from us;

6.1.4. You may choose whether you received targeted advertising from us or our partners.

6.2. Opt-out.

We may also use tracking technologies to collect information about your visits over time and across third-party services or other online services. The Network Advertising Initiative (the “NAI”) is a cooperative group of ad serving providers. The NAI has developed a set of privacy principles to which its members adhere. The NAI is committed to providing consumers with clear explanations of Internet advertising practices and how they affect you and the Internet generally. For more information about the NAI, third party ad servers generally and the opt-out options offered through the NAI, visit http://www.networkadvertising.org/index.asp.

7. Accessing and Correcting Your Information.

If you have a Company account, you can help ensure that your contact information and preferences are accurate, complete, and up to date by logging in to your Company account or by emailing us at support@swiggle.co. For other personal information we hold, we will provide you with access for any purpose including requesting that we correct the data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.

8. What Happens to my Personal Information if I Terminate my Swiggle Account?

When your Company account is cancelled (either voluntarily or involuntarily) all of your Personal Information is placed in “deactivated” status on our relevant Company databases. However, deactivation of your account does not mean your Personal Information has been deleted from our database entirely. We will retain and use your Personal Information as necessary to comply with our obligations, resolve disputes and enforce our agreements, after which it will either be destroyed on anonymized.

9. Security of Your Information.

9.1. Security Measures.

We have put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.

9.2. No Security Guarantees.

Although we take appropriate measures to safeguard against unauthorized disclosures of Information, we cannot assure you that Information will never be disclosed, altered or destroyed in a manner that is inconsistent with this Privacy Policy.

10. Changes to the Privacy Policy.

Although most changes are likely to be minor, we may change our Privacy Policy from time to time, and in our sole discretion. We encourage visitors to frequently check this page for any changes to the Privacy Policy. Your continued use of the Service after any change in this Privacy Policy will constitute your acceptance the changes.

11. California Privacy Rights.

As mentioned above, California law permits residents of California to request certain details about what Personal Information a company shares with third parties for the third parties’ purposes. You may make such request via an email to: contact@swiggle.co. In addition, whether you have questions about our sharing practices or your rights under California law, please write us at: contact@swiggle.co

Note that although we take high measures to secure the information and reduce the risk of unwanted disclosure, we can not guarantee the information will not be exposed as a result of unauthorized penetration to our servers, or other similar causes.

12. Users From Other Jurisdictions.

By using the Service, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and consent to having your data transferred to and processed on computers located outside of your province, state, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. If you do not accept this Privacy Policy, please do not use the Service. The Service is controlled and operated by the Company from Canada. If you are not a resident of Canada or the United States or you are located outside Canada or the United States and choose to use the Service or provide information to us, please note that we will transfer the information, including Personal Information, to Canada or the United States and process it there. Your acceptance of this Privacy Policy, followed by your submission of such information represents your agreement and consent to that transfer. We do not represent or warrant that the Service, or any portion thereof, are appropriate or available for use in any particular jurisdiction. Those who choose to access the Service do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the availability of the Service, in whole or in part, to any person, geographic area or jurisdiction that we choose, at any time and in our sole discretion.

13. Changes in Our Practices.

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy on our website.  Your continued use of the Services constitutes your acceptance of the modified Privacy Policy.

14. Contact Information.

If you have any questions, feedback or to report a violation regarding the Privacy Policy, you may email us at support@swiggle.co.