Archived Privacy Policy May 25, 2018

Privacy Policy Overview

Effective from May 25th, 2018.

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 Swivl.com 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.

Summary of updates May 25th, 2018: In response to GDPR requirements, we have added better navigation, improvements in language, declared data processors and setup new internal processing for meet GDPR guidelines. (See previous policy) for reference.

Privacy Policy

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.

To opt-out of our use of cookies, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of our Services.

How we Collect, Use and Disclose 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.

What Personal Information We Collect.
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.

How We Use and Disclose 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.

How We Protect Children’s Privacy.
Our services are neither intended nor directed for use by children under the age of sixteen 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 sixteen without the appropriate consent. If a child whom Swivl knows or suspects to be under the age of sixteen 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.

Retention of Data and Authorized Data Processors
We may share your personal information with our authorized service providers (sub-processors) that perform certain services on our behalf. These services may include providing customer service, performing business analysis and supporting our website functionality or other services that are necessary to operate the site. We do not disclose any personal information to authorized service providers from Student Account holders beyond what is necessary to operate the site. See our List of Sub-processors.

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.

How To Access and Control Your Information

You, and parents of users under the age of sixteen have the right to request a copy of your information, to object to our use of your information, to request the deletion of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling legitimate interests to keep. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

You may opt out of receiving promotional communications from us by using the unsubscribe link within each email or by contacting us as provided below to have your contact information removed from our promotional email list or registration database.

Other Situations That Require Sharing Data

-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 for 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.

How we Approach 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.

Sharing & Social Media Guidelines

The Swivl uses social sharing buttons which help share web content directly to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account. Your use of these platforms is governed by their respective privacy policies and terms.

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, send an email to support@swivl.com

Contact Us

If you have any questions, please contact us at:

Swivl, Inc.
1450 El Camino Real, Menlo Park, CA 94025
support@swivl.com

For European privacy related inquiries, contact us at: eudatarep@swivl.com