Satarii, Inc. Privacy Policy

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Satarii, Inc. Privacy Policy effective August 3rd, 2015

Thank you for visiting our web site. This privacy policy tells you how we use personal information collected at this site. Please read this privacy policy before using the site or submitting any personal information. By using the site, you are accepting the practices described in this privacy policy. These practices may be changed, but any changes will be posted and changes will only apply to activities and information on a going forward, not retroactive basis. You are encouraged to review the privacy policy whenever you visit the site to make sure that you understand how any personal information you provide will be used.

*Note: the privacy practices set forth in this privacy policy are for this web site only. If you link to other web sites, please review the privacy policies posted at those sites.

Collection of Personally Identifiable Information

We collect personally identifiable information, like names, postal addresses, email addresses, images and videos of your likeness etc., when voluntarily submitted by our visitors. This information may be provided in the form of videos, comments, photos or forms that contain personal information. The information you provide is used to fulfill your specific request and for the uses outlined below. Once collected, this information is sent to our servers located in the United States.

Use of Personally Identifiable Information

We use the information we collect to provide the service or transaction you requested, and importantly, to maintain and improve the services we provide, including for example by providing you with a better user experience when accessing our services. We only use or process your information in a way that is compatible with and relevant for the purpose for which it was collected or authorized for use.

We may share your personally identifiable information with authorized third-parties, agents, or our affiliated businesses or contractors in order to provide a requested service or transaction. For example, if we need to ship something to you, we must share your name and address with a shipping company. We also use information collected from cookies and other anonymous identifiers to improve your user experience and the quality of our services.

We may collect and share personally identifiable information when we have a good faith belief that access, use, or disclosure of such information is reasonably necessary to satisfy any applicable law, rule, regulation, or enforceable governmental or administrative request, enforce our applicable Terms of Service, including investigation of potential violations, detect, prevent, or address fraud, security or technical issues, or protect against harm to the rights, property or safety of Satarii, our users or the public.

Our use of information other than for the purpose of completing a requested transaction or service is on an opt-in basis. This means that you will not receive communications from us regarding, for example, specials, new products or new services, unless you have given us affirmative permission to receive such communications.

Collection of Non-Personally Identifiable Information

For each visitor to our websites, we collect non-personally-identifiable information including IP address, profile information, aggregate user data, preferences, technical session information, browser type. This data is used to manage the website, track website usage, provide context for referring traffic sources, and improve overall website performance. This non-personally-identifiable information may be shared with third-parties to provide more relevant services and advertisements to members. User IP addresses are recorded for security and monitoring purposes. If you arrived at our website via a link from another webpage, we may receive aggregate or otherwise anonymous statistical information about your visit to our site. We monitor customer traffic patterns and site usage to help us develop the design and layout of the site, and to improve the content of our website to better match the interests of our website users.

Information Collected from Residents of the European Union

Satarii’s services are hosted and operated entirely within the United States of America, and any information you submit to us is presumed to be hosted on servers located within the USA, and you consent to this transfer of your personal information to United States jurisdiction by accessing or using our services. Please note that United States laws may vary from your national laws, and may not offer the same privacy protections as your national laws.

Satarii adheres to the U.S. – EU Safe Harbor Agreement and the U.S. – Switzerland Safe Harbor Agreement concerning the transfer of personal data to the United States of America. We follow the Safe Harbor Principles published by the U.S. Dept. of Commerce with respect to all such data. If there is any conflict between this Privacy Policy and the Safe Harbor Principles, the Safe Harbor Principles shall govern. Our Safe Harbor certification may be reviewed at the U.S. Dept. of Commerce Safeharbor website, and more information about the Safe Harbor Principles may also be found by visiting the U.S. Dept. of Commerce.

Satarii shall refer unresolved privacy complaints received under the Safe Harbor Agreement to the independent dispute resolution program BBB EU Safe Harbor Program as administered by the Council of Better Business Bureaus. If your complaint is not resolved to your satisfaction through our internal dispute resolution efforts, then please visit consult with the BBB EU Safe Harbor program for more information or to file a complaint.

Use of Cookies

Satarii uses cookies to store visitors’ preferences and to record session information, such as shopping cart items, for purposes including ensuring that visitors are not repeatedly offered the same advertisements and to customize newsletter, advertising, and Web page content based on browser type and user profile information. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. You may be able to configure your browser to accept or reject all or some cookies, or notify you when a cookie is set, so check the “Help” menu of your browser to learn how to change your cookie preferences.

Our Commitment To Children’s Privacy

The Children’s Online Privacy Protection Act (COPPA) was created to protect children under the age of thirteen from unsuspecting practices related to collecting, using, or disclosing any information about them. Our services are neither intended nor directed for use by children under the age of thirteen. Satarii does not knowingly accept, collect, maintain or use any information from any child under the age of thirteen, and if a child whom Satarii knows or suspects to be under the age of thirteen sends personal information to us online, we will only use that information to respond directly to that child, notify the parents, or seek parental consent.

Distribution of Information

Except as stated in our Privacy Policy, we will not disclose personally identifiable information about our users to any third party without your prior consent.

We share personally identifiable information with third parties only to the extent necessary to render services you have requested, for example to trusted business partners who process information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.

We may share non-personal, aggregate information regarding customer demographics, traffic patterns, sales, and site usage with our partners, advertisers or sponsors. We may offer some services on or in collaboration with other Internet web sites. Personally identifiable information that you provide to those third-party sites may be sent to us so that we can deliver the requested service. We process such information under our Privacy Policy.

We may also provide you with access to third party applications, such as gadgets or extensions, through our website. Any information collected when you enable a third party application on our site is processed under our Privacy Policy, but any information collected by a third party application provider is governed by their privacy policies.

We may also share your personally identifiable information with third parties if we have a good faith belief that access to or use of this information, or the preservation or disclosure of this information is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request; to enforce our Terms of Service, including for investigation of possible violations; detect, prevent, or otherwise remedy fraud, security threats or breaches, or other technical issues; and to prevent harm to the personal or property rights of Satarii, or other third parties, as permitted by applicable laws.

Satarii Security

Your personally identifiable information is kept secure. Only authorized employees, agents and contractors (who have agreed to keep information secure and confidential) have access to this information. Specifically we take the extensive steps outlined below to ensure security.

Satarii Security Overview

Swivl Cloud runs on Amazon EC2 Compute Cloud for the core application. Swivl Cloud uses Amazon S3 for storing your video. Amazon states that they have highly secure data centers which utilize state-of-the art electronic surveillance and multi-factor access control systems, that its data centers are staffed 24×7 by trained security guards, and access is authorized strictly on a least privileged basis. You can learn about Amazon’s security at the AWS Security Center. AWS has achieved ISO 27001 certification and has been validated as a Level 1 service provider under the Payment Card Industry (PCI) Data Security Standard (DSS). AWS undergoes annual SOC 1 audits and have been successfully evaluated at the Moderate level for Federal government systems as well as DIACAP Level 2 for DoD systems. Access to Swivl Cloud data portal management is limited to several key employees and is protected by a two-factor authentication mechanism for access, requiring authorized team members to first log in using their email address and password, then enter a six-digit access code that refreshes every 30 seconds from a linked mobile device. All private data exchanged with Swivl Cloud is always transmitted over SSL. For API connectivity between Swivl Capture app and Swivl Cloud, we use OAuth authentication occurring over SSL protocol.

User Video Access 


Other Cloud users can’t see your projects unless you deliberately share public links to projects or share projects via email or group. If a video is shared with a specific user via email, if someone else gets this email, they will be unable to access the video unless they have login credentials of that user. Public projects are only viewable by people who have a link to the project(s). Videos that are deleted by the user are retained for 30 days for recovery purposes due to accidental deletion (per user request) and then removed permanently from the Swivl Cloud storage servers. Swivl Cloud user listings are not available or visible to individual users and thus all student data is hidden

Only Swivl Cloud Institutional Account administrators have additional visibility to their member data, 
but it is specifically configured by each administrator and has to be explicitly accepted by each Institutional Account member.

Company Policies 

Satarii employees are prohibited from viewing the content of files you store in your account. Employees may access file metadata (e.g., file names and locations) when they have a legitimate reason, like providing technical support. Like most online services, we have a small number of employees who must be able to access user data for the reasons stated in our privacy policy (e.g., when legally required to do so).

A very select number of employees (senior engineering leadership) have the ability to access video data only when legally required or requested by customer for technical support.

Privacy Contact Information

If you have any questions, concerns, or comments you may contact us at service@swivl.com.

We reserve the right to make changes to this policy. Any changes to this policy will be posted.