These updates were effective July 28, 2023
At Swiftly, Inc. (“we,” “us,” or “our”), we take your privacy seriously. Please read this privacy policy (“Privacy Policy”) to learn how we treat your Personal Data (as defined below) when you use our website at https://www.goswift.ly/ (the “Website”), use our mobile application (the “App”), request a demo, download our software, subscribe to one of our product lines, log into your account, submit an inquiry to us, or otherwise access or use the various content, features, software, or other services offered by us through the Website, App, and related applications and software (collectively, the “Services”).
Remember that your use of the Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use, which can be reviewed here.
You may print a copy of this Privacy Policy by clicking here. If you have a disability, you may access this Privacy Policy in an alternative format by contacting us using the information at the end of this Privacy Policy.
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not apply to information that you provide to or that is collected by any third party that we don’t own or control, including people we don’t manage, even if you access such third parties through the Services. This Privacy Policy does not apply to the extent that we process Personal Data in the role of a processor (or a comparable role) on behalf of our customers, including where we offer to our customers various software-as-a-service products, through which our customers collect, use, share or process Personal Data via our Services. If your Personal Data has been submitted to us by or on behalf of one of our customers and you wish to exercise any rights you may have under applicable law, please inquire with the applicable customer directly.
The chart in this section details the categories of Personal Data that we collect and have collected over the past 12 months:
1.Category of Personal Data
2. Source(s) of Personal Data
3.Categories of Third Parties With Whom We Share this Personal Data for a Business Purpose:
Personal identifiers
You
Third Parties
Service Providers
Acquirors
Selected Recipients
Internet or other similar network activity information
You
Third Parties
Service Providers
Acquirors
Selected Recipients
Sources of Personal Data We Collect (Column 2 above)
We collect Personal Data about you from the following categories of sources:
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, to analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).
We process Personal Data to operate, improve, understand and personalize our Services. We use Personal Data for the following purposes:
We will not collect additional categories of Personal Data or use the Personal Data we collect for materially different, unrelated, or incompatible purposes without providing you notice.
Categories of Third Parties with Whom We Share Personal Data (Column 3 above)
We disclose your Personal Data as indicated in the chart above to the following categories of service providers and other parties:
We disclose your Personal Data to service providers and other parties for the following business purposes:
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins or extensions, or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp), and the Digital Advertising Alliance (optout.aboutads.info). Some of the companies we work with may offer their own opt-out mechanisms, such as Google. You can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.
We may communicate with you, if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive marketing and other optional communications from us, please use the “unsubscribe” link at the bottom of any such email or contact us via the means indicated in this Privacy Policy.
Our App or other portions of the Services may send push notifications to your device. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the App, some software, or other Services (such as receiving a notification that a transit line is approaching).
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in a de-identified or aggregated form where that information would not identify you personally.
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us via a means indicated at the end of this Privacy Policy.
If you are a California resident, you have the rights set forth in this section, including the right to access the Personal Data we hold about you, to ask that your Personal Data be corrected, updated, ported, or erased, and to opt out of the sale of your Personal Data. You also have the right to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes. For this section of the Privacy Policy only, “Personal Data” shall have the meaning given to the term “Personal Information” in the CCPA. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights.
Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. When we process Personal Data on behalf of our customer, we are acting as a service provider to the customer. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us.
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third-party recipient.
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Under California law, some of the data we share with our advertising partners may qualify as a “sale” as defined under the CCPA. If you are accessing our site from the state of California and would like to exercise your right to opt-out of such “sale”, please click on the “Do Not Sell My Personal Information” link in our website's footer or in the cookie settings banner on our website.
To exercise the rights described above, including the rights to data portability and correction, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request by emailing us using the contact information provided in the “Contact Information” section of this Privacy Policy.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us via the means indicated at the end of this Privacy Policy, with “Nevada Do Not Sell Request” indicated in the subject line, and providing us with your name and the email address associated with your account. Additional verification of your identity may be required. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
We are based in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, retention, and sharing that differ from U.S. laws and you provide Personal Data to us, please note that any such Personal Data that you provide to us may be transferred to the United States of America. By providing such information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, retention, and sharing set forth herein. We safeguard and enable the global transfer of Personal Data in a number of ways.
The following applies to individuals in the European Economic Area (EEA) or the United Kingdom.
We are required to inform you of the lawful basis of our processing of your Personal Data, which are described in the table below. If you have questions about the lawful basis of how we process your Personal Data, contact us at the address listed in the section titled “Contact Information” below.
Processing Purpose
Lawful Basis
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated on the Services.
Processing is necessary for the performance of a contract. You are subject to a contract with us and we need to use your Personal Data toprovide services.
Processing is necessary to comply with our legal obligations.
Processing activities constitute our legitimate interests. We consider and balance the potential impact on your rights before we process your Personal Data for our legitimate interests. We do not use your personal Data for activities where our interests are overridden by the impact on you (unless we have your consent, or we are otherwise required to perform a contract or by law).
We will use your Personal Data only for the purposes for which we collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider deidentification, aggregation, and anonymization of Personal Data to be compatible with the purposes listed above and in your interest, because the deidentification, aggregation, or anonymization of such data reduces the likelihood of improper disclosure of such data.
PLEASE NOTE WE MAY PROCESS YOUR PERSONAL DATA WITHOUT YOUR KNOWLEDGE OR CONSENT, IN COMPLIANCE WITH THE ABOVE RULES, WHERE THIS IS REQUIRED OR PERMITTED BY LAW.
European data protection laws give you certain rights regarding your Personal Data. You may ask us to take the following actions in relation to your Personal Data that we hold:
When we receive your request, we may ask you to verify your identity before we can act on your request. We may withhold information where we are required by law to do so or if the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested.
If you are a resident of Europe and would like to exercise any of these rights, please submit your request to the address listed in the section titled “Contact Information” below. If you would like to submit a complaint about our use of your Personal Data or response to your requests regarding your Personal Data, you may contact us or submit a complaint to the data protection authority in your jurisdiction. You can find your data protection regulator in the EEA here. In the United Kingdom, you can find your data protection regulator here.
Our Services may contain links to other websites, such as social media platforms or advertising partners. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.
We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Website, by sending you an email and/or by some other means. Please note that if you haven’t provided us with your email address, you may not directly receive certain legal notices. Such legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them once they are made publicly available.
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: support@goswift.ly.
