About | Terms and Conditions | Privacy Policy

PRIVACY POLICY

 

This Privacy Policy aims to protect your privacy and personal information when using our Services.

 

This Privacy Policy forms an inseparable part of our Terms of Use and shall be interpreted and applied together with all provisions of our Terms of Use, especially but not limited to the Definitions set out therein.

 

Personal Information”, we mean information relating to you or other identifiable individuals.

 

By accessing and using our Services you give your irrevocable consent to the terms of the present Privacy Policy.

 

We reserve the right, at any time, to update and change any or all provisions of this Privacy Policy in our sole discretion. If we do so, we will notify our users by email or other means of electronic communication of any changes that in our sole discretion is material to this Privacy Policy. By continuing to use our Services after any such modifications, you accept and agree to such modifications. You are responsible for regularly reviewing the most current version of this Privacy Policy, which are currently available at ….

 

  1. Content of this Privacy Policy and your consent

 

1.1 This Privacy Policy describes how and when we collect, use, share, process in any other ways information you provide to us when you use our Services. SWAPPIE by its nature allows you to connect to, access and use Supported Platforms developed and controlled by other third parties. Please note that this Privacy Policy does not cover any information or other content and the processing thereof you can view via SWAPPIE on Supported Platforms (which was not posted there using SWAPPIE services) or information you provide to Supported Platforms via SWAPPIE or by other means. We do not take responsibility for the privacy policies of any Supported Platforms. Such content will be under the control of the Supported Platforms and shall be subject to the privacy policy and other terms of such Supported Platforms.

 

1.2 By using SWAPPIE and/or submitting any information, you give your consent to the collection, transfer, storage, disclosure, processing and use of your information in the manner set out in this Privacy Policy. If you do not consent to the use of your information in these ways, please stop using the Services.

 

2. Collected information

 

2.1 We collect Personal Information (such as registration and account information) from our customers and users of the Services for our own purposes, such as to provide and administer the Services (“SWAPPIE Data”).  We’re the data controller in respect of this information.

 

2.2 When you first register for a SWAPPIE account, and when you use the Services, we collect some Personal Information about you such as:

 

 

We also automatically collect and receive certain information from your mobile devices, including the activities you perform via SWAPPIE, which Supported Platforms and applications you are using with what frequency and duration, the type of hardware and software you are using (for example, your operating system or browser), and information obtained from cookies.

 

2.2 We also process Personal Information on behalf of our customers as their data processor. Such data is defined as Customer Content under our Terms of Use. Our customers control how their Customer Content is collected and used by them. In legal terms this means that our customers are the data controller of their Customer Content. Accordingly, we only use Customer Content to provide the Services to our customers in accordance with the lawful instructions they give us through the Services.

 

3. Disclosure of collected information

 

3.1 Except as provided in this Privacy Policy, we do not disclose any Personal Information gathered via SWAPPIE to third parties.

 

3.2 We may disclose information we have collected about you during or in connection with using SWAPPIE (including Personal Information) to third parties to the necessary extent in the following cases:

  1. if you explicitly gave your consent to the disclosure of such information to a third party when connecting to a third-party service that asks you if you consent to such sharing;

  2. if we are legally required to do so, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands;

  3. if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person;

  4. if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of our services infrastructure or the Internet in general;

  5. if we are acquired by or merged with another legal entity.

 

3.3 We use SWAPPIE Data for the following general purposes: 

 

 

3.4 We also use non-identifiable information gathered for statistical purposes to keep track of the number of visits to the Services with a view to introducing improvements and improving usability of the Services. We may share this type of statistical data so that our partners also understand how often people use the Services, so that they, too, may provide you with an optimal experience.

 

3.5 Customer Content may also be transferred from SWAPPIE to the third parties in control of the Supported Platforms, but only to the extent required in order for the SWAPPIE services to function properly. If you choose to instantly collect, process, share data and access Third Party Services and Supported Platform via your SWAPPIE account, you can obtain, use and analyze public Personal Information from Supported Platforms and Third Party Services and also create, input, submit, post, transmit, store, view or display Personal Information through the functionality in the Services. Such information can include Personal Information of all types, including but not limited to the following categories:

 

4. Storage and processing of collected information

 

4.1 SWAPPIE services are mainly provided from our office in Delaware. However, by the very nature of the services, the data that is viewed, collected, stored or posted on or through SWAPPIE also needs to flow from wherever you are located in the world, to where our Supported Platforms are storing the same data (i.e. in most cases, in the United States). In addition, we may use third-party service providers to provide the necessary hardware, software, networking, storage and other services that we use to operate the SWAPPIE services. These third party providers may also access, process, or store information collected and processed under the terms of this Privacy Policy.

 

4.2 By using SWAPPIE and/or by submitting any Personal Information, you authorize us and our third party service partners to process your information collected under the terms of this Privacy Policy (including any Personal Information) in the countries we are and they are located and to the extent necessary for the provision of our services. If you are located in the European Economic Area you hereby give us your consent to legitimize data transfers from the EEA to the United States and other countries. Please note, that the privacy protections and the rights of authorities and government agencies to access your Personal Information in some countries may not be equivalent to those in your country.

 

4.3 We store collected information for as long as it is necessary to provide SWAPPIE services. Personal Information and other information associated with your account will be kept until your SWAPPIE account is deleted, however please note that the cancellation of your SWAPPIE account will not result the cancellation of your existing account and your information from third party Supported Platforms.

 

5. Children

 

5.1 Our Services should only be accessed by individuals of Minimum Age. “Minimum Age” may mean different ages in different countries, depending on where the individual accesses the services. For reference, “Minimum Age” shall mean (a) 14 years old for the United States, Canada, Germany, Spain, Australia, and South Korea; and (b) 13 years old for all other countries. However, if applicable law requires that you must be older than such ages in order for us to lawfully provide the Services to you (including the collection, storage, and use of your information in accordance with this Privacy Policy), then the Minimum Age would be such older age. The Services are not designed nor intended for use by children or anyone else under the age of 13.

 

6. Security

 

6.1 We use industry best practices to keep any information collected, processed and/or transmitted to the Supported Platforms secure.

 

6.2 However, please note that submission of information over the Internet is never entirely secure.  We cannot guarantee the security of information you submit when using our services whilst it is in transit over the Internet and any such submission is at your own risk, and this risk is specifically disclaimed in our Terms of Use.

 

6.3 If you are a Logged-in User, it is advisable that you log out of your account at the end of every session and not leave a logged-in account unattended for any period of time, particularly if you use a shared computer or device.

 

7. Cookies

 

7.1 We use tracking technology (“cookies”), including mobile application identifiers to help us recognize you across different Services, to monitor usage and web traffic routing for the Services, and to customize and improve the Services. By using the Services you agree to the use of cookies. Cookies are small text files placed on your device when you visit a web site, in order to track use of the site and to improve your user experience.

 

8. Email preferences

 

8.1 You may opt out of marketing communications sent by us by managing your email preferences at your settings, or by following the unsubscribe instructions included in each marketing email.

 

9. Your rights

 

9.1 You can contact us to obtain a copy of the Personal Information held about you by us. This may be subject to a fee not exceeding any prescribed fee permitted by applicable law. You can also ask us to correct and, where relevant, erase that information. Please note that certain Personal Information may need to be retained by us for a period of time following cancellation of your account where this is necessary for our legitimate business purposes or required or authorized by applicable law. As mentioned above you have a right to change your email preferences at any time.

 

9.2 You should be aware that we act as a conduit between our users and the various Supported Platforms and Third-Party Apps. In several instances, the content published via our Services will not be in our custody or control, and any content that has been shared by you through any Supported Platform or Third-Party Apps via the Services may continue to be available to third parties and the public at large, as this content is now under the control of the operators of the Supported Platforms and/or the Third-Party Apps.

 

9.3 If you have any questions about this Privacy Policy, please contact: ….


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