SWYM PRIVACY POLICY

(Last Updated and Effective: May 15, 2018)

Swym Corporation (“Swym,” “we,” “our,” or “us”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of information we receive from users of our website and services (collectively, the “Services”). We collect and use information from visitors to our website. We also collect, maintain, and process information submitted by our Clients using our Services. We provide Clients with business to business data analysis regarding our Client’s customers and visitors to our Client’s websites (“Customer Data”). If you believe we maintain your personal information, this Privacy Policy describes your options for accessing, limiting the use and disclosure of, and deletion of your personal information.

 

We understand that you value your privacy, and we want to help make your experience with our Services satisfying and safe. This Privacy Policy may be updated from time to time. For example, we may update this Privacy Policy to reflect changes to our information collection and use practices. If we make any material changes we will notify you by email (sent to the email address specified in your account, if any) or by posting the revised policy on this web page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service.

 

Categories of Information We Collect

Information You Provide to Us

We collect certain information you provide directly to us when using the Services, such as when you send a communication to us or submit a Subscription Order. The information we collect may include your personal and/or company name, telephone number, email address, postal address, payment information and other information you choose to provide.

Information Collected Automatically

Aside from the information that you provide us, we also automatically collect certain information when you use the Services or visit one of our Client’s websites. This information includes the following:

  • Device Information: We collect certain information about the devices you use with the Services, including such data as unique device identifiers, device make and model, device name, push notification identifiers, MAC address, Internet Protocol (IP) address, carrier name, operating system and browser types (collectively, “Device Information”).
    • Usage Information: We collect information about how people use the Services. This type of information may be collected in the log files of our servers or in our analytics systems each time you interact with the Services. We may use third party services, businesses, websites, and applications (collectively, “Third Party Services”), in addition to internal tools to, among other uses, collect and analyze this information. This data may include Device Information, IP address, and cookie information.
    • Links: We may keep track of how you interact with links across our Services by redirecting links or through other means.
    • Location Information: We may also automatically collect your physical location if you choose to enable your computer or mobile device to send us location information.
    • Cookies and Other Tracking Information: Like many websites, Swym and Third Party Services may collect certain information through the use of “cookies.” These are small files that your browser places on your computer which, among other uses, allow you to sign in to your Account in a browser and maintain an identified browsing session with Swym. Please refer to the “Your Choices; Cookies” section below to learn more about disabling cookies.

Use of Information

We use the information collected through the Services for the following purposes:

  • To process requests or transactions you initiate by accessing or using the Services;
    • To monitor and analyze usage and trends in order to improve the Services, or to improve your experience with the Services, for example by providing personalized content, features, or advertisements;
    • To verify your identity, in order to protect your privacy;
    • To notify you of security alerts, important updates to our Terms of Service and Use of this Privacy Policy;
    • To update you about activity on your account, or news about Swym;
    • To reach out to you about customer service issues and respond to your comments, questions, and requests;
    • To link or combine with information we get from others to help understand your needs or provide you with better service;
    • To detect, investigate, and/or prevent fraudulent, unauthorized, or illegal activity; and
    • For any other purpose for which the information was originally collected.

 

Sharing of Information

Aside from what is otherwise described in this Privacy Policy, we will only share information about you as follows:

  • As necessary to provide the Services to you;
    • With Third Party Services, consultants, or others who are working with us and need access to such information to carry out work on our behalf;
    • In response to legal process or a request for information if we believe disclosure is in accordance with any applicable law, rule, or regulation, or as otherwise required by any applicable law, rule or regulation;
    • In order to investigate or remedy potential violations of our user agreements or policies, or to protect the rights, property and safety of Swym, our users, or others;
    • In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company; and
    • When you give us consent to do so, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.

Swym uses a variety of Third Party Services to help provide our Services, such as hosting our servers, websites, providing analytics, and searching log files. Although we try to work only with Third Party Services that share our respect for your privacy, unless required by applicable law, we do not take responsibility for the actions, content, or privacy policies of those Third Party Services. We are not responsible for any additional information you provide directly to Third Party Services. Some of these Third Party Services, such as analytics providers, may collect information about your online activities over time and across different websites, applications, or other online services when you use our Services.

Protecting and Securing Your Information Online

We take reasonable measures to ensure that your personal information is transmitted and stored securely, in order to prevent loss, misuse, and unauthorized access, destruction, or disclosure. However, please be aware that, despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.

Our Policy Towards Children

Our service is not directed at individuals under the age of 18 years old, nor do we knowingly collect personal information from children under 16. If you become aware that your child has provided us with personal information without your consent, please contact us at info@swym.it

International Users

Swym’s Services are hosted in the United States and may only be used by end users lawfully residing in the United States. If you are accessing the Services from any other region with laws or regulations governing personal data collection, use, and disclosure that differ from those of the United States, be advised that through your continued use of the Services, which are governed by U.S. law, you are transferring your personal information to the United States and you consent to that transfer.

EU Data Subject Rights

Lawful Grounds

If you reside in the European Economic Area or Switzerland (collectively the “EU”), we rely on the following lawful grounds under the General Data Protection Regulation (“GDPR”) to process (collect, store, and use) your personal data: (a) it is necessary for the performance of a contract; (b) our or a third party’s legitimate business interest; or (c) your consent. Our Clients determine the lawful grounds for the processing of personal data submitted through their use of our Services and we limit such processing to our Clients’ instructions.

Data Transfer Notice

We are located in the United States. We use model contractual clauses with our Clients to provide adequate protection for the transfer and processing of your personal data in the United States.

Individual Rights

We provide tools to our Clients to respond directly to data subject requests to access, transfer, rectify or erase their personal data, or to restrict or object to the processing of their personal data.

You may also contact us at info@swym.it to request access to, transfer of, and rectification or erasure of your personal data, or restriction of processing, or to object to processing of your personal data. Please specify the nature of your request and the information that is the subject of your request. We may require you to submit additional information necessary to verify your identity and status as an EU data subject. If we are processing your personal data for a client, we will forward your request to our client and assist the client in responding within 30 days. If you are a visitor or user of our Services, we will respond to your request directly within 30 days.

If we are processing your personal data based upon the lawful ground of your consent, you have the right to withdraw your consent for such processing at anytime without affecting the lawfulness of processing based on consent before it is withdrawn. To withdraw consent, email us at info@swym.it.

Retention

At a minimum, we will retain your personal data for a long as necessary for the purpose in which it was collected such as to perform a contract, for our or a third party’s legitimate interest, or your consent. Unless you request deletion of your personal data sooner, we may hold your personal data for 365 days after a client stops using our Services.

Your Choices; Cookies

  • Submission of Personal Information. You may, of course, decline to submit information through the Services, but we may not be able to provide all or a portion of the Services to you.
  • Cookies. You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies in the browser settings if you prefer. If you choose to decline cookies, you may not be able to sign in or use certain Services and/or Third Party Services features that depend on cookies.
    • Contact Us. If you receive commercial e-mail from us, you may unsubscribe at any time by following the instructions contained within the e-mail. You may also opt-out from receiving commercial e-mail from us, and any other promotional communications that we may send to you from time to time by sending your request to us by e-mail at info@swym.it or by writing to us at: Swym Corporation, Attn: Privacy, 1100 Campus Parkway, Seattle, WA.