Privacy Policy Overview

This policy (collectively, the “Privacy Policy”) tells you how Swivl ("Swivl", "we" or "us") uses personal information collected on this website (collectively the “site” or “website”).

Swivl is a Privacy Pledge Signatory and works to safeguard student privacy regarding the collection, maintenance, and use of student personal information.

This is an e-commerce site. This site does not collect educational records for any purpose. The policies are separate and unique from our service offerings, which are intended for users in educational settings, including Swivl Cloud and Swivl Recap. When you click on a link from to either Swivl owned service offering, you are going to a separate site and your use will be governed by the terms of that site and no longer be governed by the terms of this site. Please refer to the posted policies and terms of each site for more information.

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.

We may revise and update this Privacy Policy from time to time in our sole discretion. All changes are effective immediately when we post them. Your continued use of the site following the posting of a revised Privacy Policy means that you accept and agree to the changes. 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. Any changes to this policy will be posted on this page.

*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.

Privacy Policy

Updated August 8th, 2016.

Use of Cookies/Do Not Track. Swivl 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 personal 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. We do not respond to "do-not-track" signals or other mechanisms that allow users to signal their preferences on the collection of their personal information over time and across third-party web sites or online services.

Collection, Use and Disclosure of Non-Personal 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 ("non-personal information”). If you arrived at our website via a link from another webpage, we also may receive aggregate or otherwise anonymous statistical information about your visit to our site. We also use information collected from cookies and other anonymous identifiers to improve your user experience and the quality of our services. If you give us personal information, we may remove the identifiers and aggregate it, in which case it also becomes non-personal information. Because non-personal information cannot be used to identify a particular individual, there are no restrictions on how we may use and disclose it. For instance, we may use non-personal information to manage the site, track site usage, provide context for referring traffic sources, and improve overall site performance. We may share non-personal information to third-parties for any reason, including with our partners, advertisers or sponsors.

Collection of Personal information. We collect personal information ("personal information”), like names, postal addresses, email addresses, images and videos of your likeness etc., only when voluntarily submitted by you. We may offer some services on or in collaboration with other Internet web sites, or through third party applications such as gadgets or extensions. Personal 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 this Privacy Policy. Any information collected when you enable a third party application on our site is processed under our Privacy Policy. However the use of that information by the third party application provider to whom it is given is governed by their privacy policies. We also may collect and store personal information about other people that you provide to us.

Use of Personal Information. We only use or process personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized for use. We may use personal 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 may use your personal information to respond to your requests. 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.

Authorized service providers. We may share your personal information with our authorized service providers that perform certain services on our behalf. These services may include providing customer service and marketing assistance, performing business analysis, supporting our website functionality, and supporting contests, processing payments, sweepstakes, surveys and other features offered through our website now or in the future.

Business partners. We may share personal information with the businesses with which we partner to offer certain products, services, and promotions. When you elect to engage in a particular offer or program from a third party (for example, through any link that may appear on our website), you authorize us to provide your email address and other information to that third party.

We also may disclose your information:

- In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

- When we believe disclosure is appropriate in connection with efforts to investigate, prevent, report or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Legal Terms or other agreements or policies.

- In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Information Collected from Residents of the European Union. Swivl'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. By submitting information to us you consent to this transfer of your personal information to the United States. Please note that United States laws may vary from your national laws, and may not offer the same privacy protections as your national laws.
Swivl 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. Information about the Safe Harbor certification program may be reviewed at the U.S. Dept. of Commerce Safe harbor website, and more information about the Safe Harbor Principles may also be found by visiting the U.S. Dept. of Commerce. Swivl 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.

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 unless instructed by an educator or educational institution. Swivl does not knowingly accept, collect, maintain or use any information from any child under the age of thirteen without the appropriate consent. If a child whom Swivl knows or suspects to be under the age of thirteen sends personal information to us online without appropriate consent, we will only use that information to respond directly to that child, notify the parents, or seek parental or other appropriate consent. Parents can at any time request deletion of data or of the entire account.

Security. We have implemented generally accepted standards of technology and operational security in order to protect personal information from loss, misuse, alteration, or destruction. We will use our reasonable efforts to limit access to your personal information to our authorized personnel and third party vendors, and these employees and vendors are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal information.

California Privacy Rights. California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to or write to us at Privacy, Swivl, 1450 El Camino Real, Menlo Park, CA 94025


If you have any questions please send an e-mail to