Privacy Policy

 

This Privacy Policy (the “Privacy Policy“) describes the types of information SwiftConnect Inc. (“SwiftConnect” or “we“) collects from you, or from subscribers (“you” or “your“) to SwiftConnect’s website(s) and software applications, including the enhancements, features, related website, and contents (the “Services“). It also describes how we use and disclose such information, as well as your rights with respect to SwiftConnect’s collection, use, and disclosure of such information.

We understand the importance of your privacy and the privacy of visitors to your business location who access the Services (“Visitors“) and we treat all information we receive in a responsible manner. By downloading or accessing the Services, you agree that we may collect, use, and disclose Personal Data, Aggregate Information, and Cookies pursuant to this Privacy Policy.

Information We Collect

When you use the Services, SwiftConnect may collect these types of information:

  1. Personal Data Personal Data is any information directly or indirectly relating to an identified or identifiable individual, such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
  2. Non-Identifiable Data Aggregate Information is information about your activities on or in connection with the Services that typically cannot be used to identify, locate, or contact you or your Visitors. For example, Aggregate Information includes information regarding the frequency of use of the Services, quantity and type of data entered when using the Services, components of the Services most frequently accessed, and browser types used to access the Services.
  3. Cookies, etc. Cookies, beacons, device identifiers, or similar technologies (referred to for convenience as “Cookies“) are small pieces of data placed on your device that your web browser or device uses to access the Services and that permit SwiftConnect to track your activity on the Services. We obtain information from Cookies when, for example, you or a Visitor visit SwiftConnect’s website. You may turn off cookies in your browser or device settings, but this may limit functionality of the Services. Cookies help analyze usage and provide certain functionality. Cookies don’t contain Personal Data and for that reason, we treat Cookies in the same manner as we treat Aggregate Information. If Cookies do contain Personal Data, such Personal Data will only be used or disclosed in the same manner as other Personal Data pursuant to this Privacy Policy. Cookies cannot be used as a malicious tool.

Collecting Personal Data

SwiftConnect collects Personal Data when:

  1. You sign up for the Services
  2. You use certain features of the Services that require the collection of Personal Data in order for those features to function
  3. You or your Visitors voluntarily enter or upload Personal Data to or through the Services
  4. You communicate with SwiftConnect, whether through the Services or through another form of communication, such as e-mail, web chat or telephone.

Non-Identifiable Data

SwiftConnect collects aggregate information resulting from your use and the use by your Visitors of the Services.

Using and Sharing Personal Data

SwiftConnect uses Personal Data we collect:

  • To provide the Services
  • To improve the features and functionality of the Services
  • To communicate with you in response to any of your questions and requests
  • To personalize and enhance your experience using the Services
  • To administer and provide you with information about your account
  • To prevent fraud and abuse of the Services and to otherwise protect members and Visitors and our business
  • To administer, operate and improve the Services and for internal business purposes
  • To generate and review reports and data about our user base and service usage patterns
  • To provide relevant marketing and other information to you, but only if, and to the extent that, you have consented to us providing such marketing and other information to you in accordance with applicable laws
  • SwiftConnect may be required, or may, acting in good faith, believe it is required, to share certain information with legal authorities.

Personal Data may be disclosed to third parties for a business purpose in accordance with our Privacy Policy. SwiftConnect may share Personal Data with third party service providers as SwiftConnect deems necessary for such third party service providers to perform their duties required for the Services to function. These third party service providers are not authorized to retain, share, store or use Personal Data for any purposes other than to provide the services for which they have been retained to provide.

SwiftConnect does not sell or otherwise share Personal Data with unrelated third parties.

Where you are provided access to the Services under your company contract with SwiftConnect, SwiftConnect may disclose Personal Data with your company in relation to your use of the Services.

SwiftConnect will not keep Personal Data for longer than is legally necessary at which time it will either be deleted or anonymized. For Visitor Personal Data it is the business location that determines the length of time data is to be kept, refer to their privacy policy for more details.

Personal Data may be transferred to SwiftConnect’s affiliates or as part of a sale of substantially all of the assets of SwiftConnect. In such a case, each such party will be required to hold Personal Data and not disclose Personal Data except in accordance with terms at least as restrictive as those contained in this Privacy Policy.

Using and Sharing Non-Identifiable Data

SwiftConnect uses Non-Identifiable Data:

  1. To provide the Services
  2. To improve the Services
  3. To monitor usage of the Services
  4. To analyze usage of the Services
  5. To research, compile, and report on usage trends, user demographics, and user behaviors
  6. For other legitimate business purposes.

SwiftConnect may share Non-Identifiable data with its affiliates and certain third parties, such as investors, potential investors, and third party service providers we use to provide the Services.

Location Information

SwiftConnect may use the Services to collect and use location information to provide certain functionality, such as identifying a Visitor sign-in at a specific business location. All such information will be governed by this Privacy Policy.

External Links

The Services may contain links to third party websites operated by other people or companies. We do not guarantee that we have endorsed or reviewed any links to third-party websites. SwiftConnect is not responsible for those websites, and links to such websites are solely for your convenience. We cannot control nor are we responsible for the privacy practices or consent of these third-party websites. We suggest contacting these websites directly for information on their privacy policies.

Security and Data Protection

SwiftConnect takes appropriate security measures to protect Personal Data against unauthorized access, alteration, disclosure or destruction. Please keep your password secure. Do not share your password with anyone else. No internet or email transmission is ever fully secure or error free.

Such measures include internal reviews of SwiftConnect’s data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where Personal Data is stored.

Data Processing and CCPA

The California Consumer Privacy Act (“CCPA”), which is effective as of January 1, 2020, regulates how SwiftConnect handles personal information of California residents and gives California residents certain rights with respect to their personal information.

SwiftConnect is both a “business” and a “service provider” under the CCPA. The following supplemental section applies to information we collect in our role as a business.

The general privacy policy shall continue to apply to the extent that it applies to you as a resident of California. If you are a resident of California, we are required to disclose certain uses and disclosures in a certain format, as well as to inform you of certain rights you may have.

Information We May Collect:

We may collect the following categories of information:

  • Identifiers
  • Demographic Information
  • Commercial Information
  • Internet or other electronic network activity information
  • Geolocation data
  • Audio, electronic, visual, or similar information
  • Professional or employment-related information

For each category of information, we collect the information from a variety of sources, including directly from you, from your devices, from your social media profiles, and/or from third party providers. We collect the information to provide you with services, protect our customers and ourselves (including the services), and to improve the services. We do not share personal information with Third Parties as the term is defined under the CCPA.

For more information, please refer to https://oag.ca.gov/privacy/ccpa

Data Processing and GDPR

SwiftConnect is a data processor and not the data controller for Visitors’ Personal Data. This means that SwiftConnect performs operations on Personal Data, but it does not control your Visitors’ Personal Data. With respect to Visitors’ Personal Data, the controller is the party whose business location the Visitor has visited to interact with the Services.

If you are a Visitor to a business location that uses the Services, by accessing the Services at such location (such as by signing in or using the functionality of the Services), you may be sharing your Personal Data with such business. The business’ use and disclosure of Visitors’ Personal Data is governed by such business’ privacy policy or other agreement which you may have entered into with such business. Notwithstanding that such agreement may have been presented to you through the Services, SwiftConnect is not an affiliate of such business and is not responsible for the business’ access, use, and disclosure of Visitors’ Personal Data.

SwiftConnect processes Personal Data only for the purposes for which it was collected and in accordance with this Privacy Policy. SwiftConnect takes reasonable steps to ensure that Personal Data we process is accurate, complete, and current.

To the extent SwiftConnect has access to, or processes Personal Data for individuals who are subject to General Data Protection Regulation, (commonly referred to as “GDPR”), Personal Data originating from the European Union, SwiftConnect will adhere to the requirements of GDPR.