Swapsy, Inc., a Delaware corporation ("Swapsy," "we," "us," and "our"), takes your privacy very seriously. This Privacy Policy applies to www.swapsy.com and all related subdomains (the "Site"), as well as the services available on the Site (the "Services"). Terms used but not defined in this Privacy Policy have the meanings assigned to them in the Swapsy Terms of Use. Specific features of the Site may have additional policies associated with them, and such additional policies will be prominently posted or otherwise made available to each user ("you" and "your," including any entity you represent) and are incorporated herein by reference.

We are committed to protecting our customers’ privacy and security. This Privacy Policy explains how we may collect, retain, process, share, and transfer your Personal Information when you use the Site or the Services. This Privacy Policy applies to your Personal Information when you use the Site or the Services, and does not apply to online website or services that we do not own or control, including information that you provide to a third-party service provider related to or whose services are incorporated into the Services.

This Privacy Policy is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use the Site or the Services. We may, in our sole and absolute discretion, change or modify this Privacy Policy and any policies or agreements which are incorporated herein, at any time, and such changes or modifications shall be effective immediately upon posting on the Site. No revision or update will apply to a dispute of which we had actual notice on the date we post the changes or modifications. We will notify you of such changes or modifications by posting them to the Site, and your use of the Site or the Services after such changes or modifications have been posted shall constitute your acceptance of the Privacy Policy last revised. If you do not agree to the Privacy Policy as revised, do not use (or continue to use) the Site or the Services.

Definitions

"Account" means the user profile that you have registered for through the Site.

"Personal Information" means personal information that can be associated with an identified or identifiable person, and can include name, postal address, telephone number, email address, financial account information, account number, date of birth, Technical Usage Data, and data contained in government-issued credentials (e.g., driver’s license number). Personal Information does not include information that does not identify a specific user (i.e., anonymized data).

"Technical Usage Data" means information that we collect from your phone, computer, or other device that you use to access the Site. Technical Usage Data tells us how you use the Site and the Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Site, and other usage and browsing information, such as information collected through the use of Cookies.

Information we collect:

Personal Information

When you create an Account, we will collect Personal Information, which may include:

• Name
• Mailing address
• Email address
• Telephone number
• Bank account number
• Credit or debit card number
• Date of birth
• Social security number (or other government-issued identification numbers)
• Information listed on various forms of government-issued forms of identification

We also collect information that you provide and upload to the Site through the submission of User Content or through your communication with us.

We collect Technical Usage Data, which may constitute Personal Information if the Technical Usage Data may be used to identify you. This Technical Usage Data may be collected by us, through the use of cookies, analytics tools, third-party sources, and third-party services providers.

In order to use certain features of the Site, you may be required to provide Personal Information. If you elect not to provide such Personal Information to us, you may not be able to receive some or all of the Services. This required Personal Data may include:

• Name
• Mailing address
• Email address
• Telephone number
• Demographic information
• IP addresses
  

We may also obtain from third parties, such as identity verification services, electronic database services, and credit reporting agencies.

Why we collect and retain Personal Information:

We collect and retain Personal Information to fulfill our legal and regulatory obligations, as well as for other business purposes. We may retain Personal Information for periods longer than required by law if not prohibited by law. We will, at all times, use and disclose such Personal Information in accordance with this Privacy Policy.

How we use Personal Information:

We use Personal Information to provide the Services to you and for business management, marketing, and other reasons. We may also analyze Personal Information to improve the Services. Specifically, we use Personal Information in the following ways:

• To process Transactions
• To collect payment for your use of the Services
• To allow our partners to fulfill their promotional obligations to you
• To communicate with you to address your support requests and to provide you with other information
• To ensure compliance with legal requirements, such as "know-your customer" and anti-money laundering requirements
• To conduct criminal background and other verification checks
• To protect our legal rights
• To manage risk and to protect the Services from fraud, abuse, and unlawful conduct
• To personalize your experience with the Services
• To improve the Services
• To market the Services to you and other users

Anonymized Data

We also collect and utilize data that may not be used to identify you individually when you visit the Site or use the Services. We may use this anonymized data for any business purpose.

How we market to you:

Notifications

We may occasionally send you push notifications through our mobile applications to send you marketing messages and other notifications related to the Services or Transactions. You may, at any time, opt-out from receiving these types of communications by turning them off at the device level through your settings or through the mobile application settings.

Cookies and Log Files

We and our third-party service providers, including our marketing partners and analytics providers, may also use cookies, web beacons, tags, scripts and similar technology ("Cookies"). Cookies are small data files that are placed on your computer or mobile device to, among other things, administer the website, track and analyze trends in your use of the Site and other websites, remember your preferences when you return to the Site, and gather information about our users as a whole. The information that we store in Cookies that we place may include your email address. We may receive reports about our users from third-party service providers based on their use of Cookies on an individual or aggregated basis. In addition, some of our third party advertising vendors or partners show our ads on sites across the Internet. These vendors or partners may use Cookies to gather information about your activities on the Site and other websites in order to provide advertising based on your browsing activities.

You are free to decline Cookies if your browser permits, but doing so may interfere with your use of the Services. The use of Cookies by our third-party service providers is not covered by this Privacy Policy. We do not have access to or control over the Cookies they use, but you may be able to opt out of some of their practices by visiting: http://preferences-mgr.truste.com/ or http://www.networkadvertising.org/managing/opt_out.asp. Please note that opting out does not prevent the display of advertisements to you.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include your IP address, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. From time to time, we may combine this automatically collected data to other information we collect about you for reasons such as analysis, security, content generation, or marketing.

We may use mobile analytics software to allow us to better understand the functionality of our mobile software on your mobile device. This software may record information such as how often you use the mobile applications, the events that occur within the mobile applications, aggregated usage, performance data, and from where the mobile application was downloaded. We may link the information we store within the analytics software to any Personal Information that you submit within the mobile applications.

We currently do not recognize "do-not-track" signals from your browser. We engage third parties, such as marketing or analytics partners, who may collect information about your online activities over time and across different websites when you use our websites. We use local storage objects, such as Flash Cookies and local storage, such as HTML5, to prevent unauthorized or fraudulent sign ups. Third parties with whom we partner to provide certain features on our websites or to display advertising based upon your web browsing activity may also use Flash Cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 and local storage artifacts. For more information, please click here: http://www.macromedia.com/support/documentation/en /flashplayer/help/settings_mana ger07.html.

How we share information with others:

Our website may offer publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Please do not post any information you prefer to keep private, including but not limited to your email address, mailing address, or Swapsy Transaction information.

Access to your information

If your Personal Information changes, or if you no longer wish to use our Services, you can access, modify, delete or update your Personal Information submitted on our Site by logging into your Account and changing your preferences or by contacting Swapsy Customer Service at [email protected]. We will respond to your request within a reasonable timeframe.

How we protect your information:

We maintain technical, physical, and administrative safeguards and procedures that are designed to provide protection for your Personal Information against loss, misuse, unauthorized access, disclosure, and alteration, and that are appropriate to the nature and sensitivity of your Personal Information. The safeguards that we maintain include firewalls and information access authorization controls. We employ Secure Socket Layer (SSL) encryption technology to protect the Personal Information transmitted on the Site. While we are dedicated to securing our systems, you are responsible for securing and maintaining the privacy of your Account information.

Choices you can make about our use of your information:

You have the right to request access to the Personal Information that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of such Personal Information. You may have the right to request a copy of the Personal Information that we have collected about you, and to have any inaccuracies corrected. You may also request that we cease processing your Personal Information. Nothing in this Privacy Policy shall affect our obligation to retain certain Personal Information where required by law.

If, after giving us your permission to share your Personal Information with third parties with whom we market our jointly-offered products, you later decide that you no longer want us to share such Personal Information, you may contact us using the information below.

Complaints

If you have a complaint regarding the Site or the Services, please contact Swapsy Customer Service at [email protected]

Third-party sites

The Site may contain links to other websites. We are not responsible for the privacy practices or the content of these other websites. We encourage you to familiarize yourself with the privacy practices of these other websites prior to engaging with them or submitting your Personal Information to them.

Referrals

If you choose to use our Refer a Friend program to tell a friend about our Services, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Site. We store this information for the sole purpose of sending this one-time email and tracking the success of our Refer a Friend program. Your friend may request removal from our Refer a Friend program by following the instructions in the promotional email message we send out and providing the required information.

Import contacts

You can import contacts from your Outlook or other email account address book in connection with using our Services. We collect the username and password for the email account from which you import your contacts and will only use it for that purpose. We may also collect the name, mailing address, email address, and telephone number(s) of any contacts that you import in order to facilitate the Services.

Changes to this policy; Transfer of Information

We may amend this policy at any time, and shall notify you by posting a revised version on our websites. Should we make a substantial change to the manner in which we collect, use, or store Personal Information about you, we shall provide prior notice on our websites, or by email.

If we are involved in a reorganization, merger, acquisition or sale of our assets, your information may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.

Contact

You can contact us with any questions or concerns about this Privacy Policy at:

Swapsy, Inc.
Attn: Customer Service
888 Prospect Street Suite 200
San Diego, California 92037
[email protected]