This is the privacy policy ("Privacy Policy") that governs how we, Swifto Inc., and our affiliates and subsidiaries (collectively, "Swifto", "we", "us" or "our"), use Personal Information (defined below) that we collect, receive and store in connection with the use of: (i) the website www.swifto.com (together with its subdomains, content and services, the "Site"); and/or (ii) any mobile application that we license including, without limitation, the Swifto App (each, together with its content and services, an "App"). The Site and App are individually and collectively referred to herein as the "Service".
This Privacy Policy forms, as applicable, part of: (i) Site our terms of use, available at www.swifto.com\agreement ("Terms of Use"); and (ii) our End User License Agreement which you read and agreed to prior to downloading the App (the "EULA"). Capitalized terms used herein shall have the meaning ascribed thereto, as applicable, in the Terms of Use and EULA.
1. Introduction. We are committed to respecting your online privacy and we recognize your need for the protection and management of any Personal Information that you share with us. We provide this Privacy Policy to explain our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Service. "Personal Information" means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, personal profile, a home or other physical address, an email address or other contact information.
2. Your Consent. By using the Service, you consent to the terms of our Privacy Policy and to Swifto's processing of Personal Information for the purposes stated herein. If you do not agree to this Privacy Policy, then please do not use the Service. We reserve the right, at our discretion, to modify this Privacy Policy at any time. We will inform you regarding any modifications by either notifying you via your designated email address or by posting the changes on the Site. The modifications will become effective ten (10) days following whichever form of notification occurs first and your continued use of the Service thereafter means that you accept those changes.
3. Receipt and Collection of Information. We do not currently require you to provide Personal Information in order to have access to general information available on the Site. We may, however, receive and/or collect Personal Information from you in the following ways:
3.1. Account. In order to provide you with certain services that we offer through the Service, you must create an account (“Account”). You may create an Account by completing an online registration form or by signing in via a Third Party Account (defined below), as follows:
(a) Online Registration Form: You can complete and submit an online registration form which we make available on the Service. In certain circumstances we may also offer you the opportunity to contact a Swifto representative, by using a phone number that we display on the Site, and request that they complete abd submit the online registration form for you. In any event, you will be asked to provide us with information such as your Service user name, an email address, and a password that you will use for your Account. If you complete and submit the online registration form with the assistance of a Swifto representative you must immediatley access your Account and change your password (you agree that Swifto shall not be liable, and you hereby waive any legal or equitable rights or remedies you may have against Swifto, in connection with any failure by you to change your password).
(b) Third Party Account: You can click on a sign-in option that we may display on the Service for Facebook or other designated third party websites that you may have registered an account with (each a "Third Party Account"). Doing so will enable you to link your Service Account and your Third Party Account. If you choose this option, then a Third Party Account pop-up box will appear which you will need to approve in order to proceed, and which will describe the types of information that we will obtain from, and the types of activities that we may perform in connection with, your Third Party Account. Such information may include your Third Party Account user name, email address, profile picture, birthday, gender and preferences. Please note that in order to use this option, you will need to have, and may need to be signed-in to, an existing Third Party Account.
Regardless of which method you choose to register your Account, you may also be asked to provide us with certain mandatory information, such as your cell phone number and your address. We may send an email to your nominated email address to confirm, or instruct you how to confirm, your registration.
3.2. Dog Walking Services.
(a) General. We offer certain services through the Service. Such services include the "Dog Walking Service" which is an informative platform that enables registered Service users who are seeking a dog walker ("Seekers") to send and post requests for a dog walker ("Dog Walker") through the Service, (each a "Request"), and enables Dog Walkers to respond through the Service to a Request with offers to provide dog walking services. We collect, receive and store Personal Information (such as your email address and cell phone number) in connection with the services that we provide to you. Your participation in any services is optional and you at all times may choose whether to provide any related Personal Information.
(b) Seekers. If you are a Seeker then, in order to receive the full benefit of the Dog Walking Service, it may also be necessary to provide us with certain information about your Request, such as: your name, the consideration that you are willing to pay for the dog walk, the number of participating dogs, the general health and any behavioral issues of the dog(s), the duration of the dog walk and the location at which the dog walk will take place (including information necessary for the Dog Walker to gain access to the dog(s)).
3.3. Location Based Services. Certain location-based services that we provide in connection with the App are dependent on data related to the geographic location of the device on which the App is installed. Please be aware that unless the location feature is turned off on your device, we may continue to collect such location data. If you choose to participate in these location services, you agree that we may collect location data from your device.
3.4. 'Contact Us' Information. If you send us a "contact us" request we will receive and store a copy of your email address, as well as any other Personal Information you disclose.
3.5. Profile. The Service enables you to build a profile in connection with your Account ("Profile"). Your Profile will be based on the information that you provide to us from your Third Party Account. You may also choose to provide us with other information to use and display in connection with your Profile. If you provide information about your references or any third party, please make sure you first obtain their consent to post and make information about them publicly available. If you are a Dog Walker then, in addition to your Profile, you may also have a Dog Walker Page (see Section 4.3. below).
3.6. Transactions.
(a) The Dog Walking Service includes the option to purchase dog walking services from a Dog Walker. If you choose to purchase or provide dog walking services, we will require sufficient information from you to complete the transaction. If you are Seeker, such information could include a credit card number, related account and billing information, invoice related information, and other data required to process the order. We may update such data should you grant us permission to bill you or your credit card for recurring charges, such as monthly or other types of periodic payments. If you are a Dog Walker, such information could include your bank account name and number, your address, phone number and social security number, and such other information as may be necessary to facilitate the transfer of payments to you.
(b) We may use the tools, software or services of third-party service providers (for example, ADP® for payments to Dog Walkers, and Stripe™ for payments to us from Seekers) to process transactions on our behalf, in which case you acknowledge and agree to review and be bound by the terms of use and privacy policy of said third-party service provider. Except as set forth herein, we will not share your financial Personal Information with any third person or entity.
3.7. Cookies and Other Tracking Technologies. Some of our Site pages may utilize "cookies", log-files and other tracking technologies. A "cookie" is a small text file that may be used, for example, to collect information about Site activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a Site user. Most browsers allow you to control cookies, including whether or not to accept and remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. We may also collect limited information from your device in order to provide the App. Such information may include your device type, device id, and date and time stamps of App use. In addition, we may deploy tracking technologies within the App to help us gather aggregate statistics, but we will not use Personal Information for such purposes.
4. Publicly Available Information.
4.1. General. The Service may permit you and other Site users to post, publish and transmit information, video, image, data, text, documents, and other content onto public areas of the Service and to other Service users ("User Submissions"). You acknowledge and agree that certain User Submissions will become publicly published content and will be available to other Service users. This is the case even if your User Submission contains Personal Information. Please note that if you publish your contact information, you may receive unsolicited messages from users and visitors to the Site. We therefore encourage you to publish only information you are sure you want to be accessible to anyone.
4.2. User Submissions and Profile. Any inquiries, responses, messages, and comments that you post onto public areas of the Service will be publicly available, and may include your Profile name and Profile picture (to the extent that you have posted a Profile picture). You have the choice of deciding whether to make your inquiries, responses, messages, and comments generally available on a public area of the Service or to only send or post them to one or several Service users. The notices and tools that we provide on the Service should help inform you who your User Submissions will visible to (for example, one or many other Service users).
4.3. Dog Walker Page. For the purposes of matching Seekers and Dog Walkers Dog Walkers may have a “Dog Walker Page” which shall display information such as their picture, name, dog walking experience, a self-authored description, as well as testimonials written by Seekers who have used such Dog Walker’s services in the past. Dog Walker Pages will be accessible to all Service users and should be considered publicly available content.
5. Use of Personal Information. If you submit Personal Information to us through the Service, then such Personal Information may be used in the following ways:
5.1. We will use your Personal Information to provide (and improve) the App and Site and our related services to you, to contact you (including, for example, by email, SMS, and such other means as you may permit) in connection with the Service and its related services (including for the purpose of notifying you about offers, products and/or services which are published via the Dog Walking Service) and to identify and authenticate your access to the parts of the Service and the related services that you are authorized to access.
5.2. We may use your Personal Information to contact you in response to a "contact us" request.
5.3. If you include Personal Information in an inquiry, response, message, or comment that you (i) send or post to another Service user, then such Personal Information will be disclosed to that Service user; or (ii) post to a public area of the Service, then such Personal Information will be generally publicly available.
5.4. Requests. Depending on whether you are a Seeker or a Dog Walker, certain Personal Information shall be made available to other Service users in connection with your use of the Dog Walking Service, as follows:
(a) If you are a Seeker and you post a Request: certain information (but never your password), such as your name, postal code, and the time for the dog walk, will be made available to prospective Dog Walkers. Your email address and phone number may also be sent to the Dog Walker that confirms, via the Service, his or her acceptance of the Request.
(b) If you are a Dog Walker and you respond to or approve a Request: certain information (but never your password), such as your Profile (including your name, age, picture, postal code) and other information that you disclose, will be made available to the Seeker.
5.5. We may provide Personal Information to our subsidiaries and affiliated companies for the purpose of processing or storing such information on our behalf. Such information may be transferred to other countries around the world. We require that these parties agree to process such information in compliance with our Privacy Policy.
5.6. We may transfer your Personal Information to our third party service providers (such as a server hosting provider), but only to provide our services to you. Such information may be transferred to other countries around the world. We use commercially reasonable efforts to only engage or interact with third party service providers that post a privacy policy governing their processing of Personal Information.
5.7. We may disclose your Personal Information or any information you submit via the Service and its related services, if we have a good faith belief that disclosure of such information is helpful or reasonably necessary, to: (i) comply with any applicable law, regulation, legal process or governmental request, (ii) enforce our Terms of Use and EULA including investigations of potential violations thereof, (iii) detect, prevent, or otherwise address fraud or security issues, and/or (iv) protect against harm to the rights, property or safety of Swifto, its users, yourself or the public.
6. Use of Anonymous Information. We may use Anonymous Information or disclose it to third party service providers in order to provide and improve our Service and to enhance your experience with it. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners, for purposes including, but not limited to, targeted advertisements. "Anonymous Information" means information which does not enable identification of an individual user, such as aggregated information about the use of our Service.
7. Opt-out. We may use your email address to send you promotions, updates, a newsletter or news regarding our Service. You may choose not to receive future emails from us by selecting an unsubscribe link at the bottom of each email that you receive from us. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any "Contact Us" request as well as administrative emails (for example, in connection with a password reset request) that are necessary to facilitate your use of the Service. If you no longer desire our Service or wish to delete or deactivate your Account, you can contact us at scheduling@swifto.com.
8. Changes to Your Personal Information. To the extent that you do provide us with Personal Information, please ensure that it remains accurate. If your Personal Information changes, or you wish to remove or modify certain Personal Information that we are storing, you may either correct or update it by logging-in to your Account, which includes your Profile, and making the change(s), or by contacting us at scheduling@swifto.com. Your email should include adequate details of your request.
9. Choice. At all times, you may choose whether or not to provide Personal Information to Swifto. The notices that we provide on the Service in circumstances where we collect Personal Information should help you make this choice. If you choose not to provide the Personal Information we request, you can still use the Service, but you may be unable to access certain options, offers, and services that involve our interaction with you.
10. Collection of Information by Third-Party Sites. We may use a reputable third party to present advertisements that you may see on the Service. These third party ad servers may use cookies, web beacons, clear gifs or similar technologies to help present such advertisements, and to help measure and research the advertisements' effectiveness. The use of these technologies by these third party ad servers is subject to their own privacy policies and is not covered by our Privacy Policy.
11. Links to Other Sites. Our Service may contain links to other sites. Other sites may also reference or link to our Service. We are not responsible for the privacy practices or the content of such other sites.
12. Children's Privacy. The Service is not intended for children under the age of 13 years old, and we do not intend to collect Personal Information from anyone we know to be under 13 years of age.
13. Security. The security of your Personal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, We cannot guarantee absolute security. If you have any questions about security on the Service, you can contact us scheduling@swifto.com.
14. In the Event of Merger, Sale, or Bankruptcy. In the event that Swifto is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you and our users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control the manner in which your Personal Information is treated, transferred, or used.
15. Your California Privacy Rights. California Civil Code Section 1798.83 permits customers of Swifto who are California residents to request certain information regarding its disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to scheduling@swifto.com. Please note that we are only required to respond to one request per customer each year.
16. Commitment. We are committed to protecting your privacy. Protecting your privacy online is an evolving area, and we are constantly evolving our Service to meet these demands. If you have any comments or questions regarding our Privacy Policy, or your Personal Information that we may be storing and using, please contact us at scheduling@swifto.com. please contact us at scheduling@swifto.com. While we cannot guarantee privacy protection, we will address any issue to the best of our abilities as soon as possible.
Last modified: October 24, 2012
