Version Date: 11/26/2021
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law. Any person who provides personal information through the Website represents to us that he or she is 13 years of age or older. If we learn that personal information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the Website or has otherwise transferred personal information to the Website, please contact Sway Unlimited using our contact information below to have that child’s account terminated and information deleted.
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
Users of the Website Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, Sway Unlimited gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system and browser type, and the locations of the Web pages the user views right before arriving at, while navigating and immediately after leaving the Website. Sway Unlimited analyzes Non-Personally-Identifying Information gathered from users of the Website to help Sway Unlimited better understand how the Website is being used. By identifying patterns and trends in usage, Sway Unlimited is able to better design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, Sway Unlimited may also release the Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.
Third Party Advertisers
We use third-party advertising companies to serve ads when you visit the Website. These companies may use information (not including any Personally-Identifying Information) about your visits to this and other websites that are contained in We Cookies in order to provide advertisements about goods and services of interest to you. Using a tool created by the Network Advertising Initiative, you can opt out of several third party ad servers’ and networks’ Web Cookies simultaneously. If you would like more information about this practice and to know your choices about not having this information used by these companies, please follow the following link: http://networkadvertising.org/managing/opt_out.asp. Please contact us if you would like to know the identity of the third-party advertising companies we are currently using to serve ads.
We allow advertisers to choose the characteristics of users who will see their advertisements and we may use any of the non-personally identifiable attributes we have collected (including information you may have decided not to show to other users, such as your birth year or other sensitive personal information or preferences) to select the appropriate audience for those advertisements. We do not identify you to the advertiser.
A “Web Beacon” is an object that is embedded in a web page that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Sway Unlimited may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails, and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information; they are a technique Sway Unlimited may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information including a Web Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons, however, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered and permit you to accept or decline Web Cookies on an individual basis.
Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on our Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our Website and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.
COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. Sway Unlimited may collect a range of Personally-Identifying Information from and about Website users. Much of the Personally-Identifying Information collected by Sway Unlimited about users is information provided by users themselves at the time they register to open an account, purchase our products or otherwise interact with the Website. That information may include each user’s name, address, email address, and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender, age, date of birth, username, hometown and other demographic information, and other relevant information as determined by Sway Unlimited from time to time. Users of the Website are under no obligation to provide Sway Unlimited with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.
BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.
Sway Unlimited Communications
We may occasionally use your name and email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails at the time of registration or through your account settings, though we reserve the right to send you notices about your account even if you opt out of all voluntary email notifications.
Sway Unlimited Disclosures
Sway Unlimited will disclose Personally-Identifying Information under the following circumstances:
Marketing Communications. Unless users opt-out from receiving Sway Unlimited marketing materials upon registration, Sway Unlimited may email users about products and services that Sway Unlimited believes may be of interest to them. If a user wishes to opt-out of receiving marketing materials from Sway Unlimited, user may do so by following the unsubscribe link in email communications, by going to your account settings (if applicable) or contacting us using the contact information below.
Business Partners: When you make purchases or engage in promotions offered through our Website or our services, we may share Personally-Identifying Information with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes. When you elect to engage in a particular merchant’s offer or program, you authorize us to provide your email address and other information to that merchant.
Third Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting contests, sweepstakes, surveys and other features offered through our Website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
Changing Personally-Identifying Information; Account Termination
CONTESTS, GIVEAWAYS AND SURVEYS
COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY
We take security of your Personally-Identifying Information seriously and use reasonable electronic, personnel, and physical measures to protect it from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.