Swift App Inc.
Updated: May 12, 2023
I. WHAT PERSONAL INFORMATION WE COLLECT
"Personal Information" is data that relates to you that can identify you as an individual, either on its own or in combination with other information. Personal Information does not include data that has been aggregated or de-identified such that you can no longer be identified using means reasonably available to us. The Personal Information we actually collect depends on the nature and type of Swift Services you use or interact with. The types of Personal Information we may collect will fall in the following general categories:Profile Information: When you create or modify your account, we collect certain details such as your name, birth date, email address, phone number, postal address, profile picture, payment method, and any other information you choose to provide.
- Transaction Information: We gather specific information about your transactions made through the Swift Services, including payment method, purchase amount, date of purchase, description of the goods or services purchased, and other relevant transaction details.
- Enterprise Account Information: If you are an Enterprise Customer, we may collect sensitive personal information, including your date of birth, social security number, tax number, Employer Identification Number, and bank account information, as part of our business relationship with you.
- Usage and Preference Information: We collect information about how you and other visitors interact with Swift Services, including your preferences, expressed choices, and selected settings. In some cases, we utilize technologies like cookies, pixel tags, and similar tools to generate and maintain unique identifiers. For more details on these technologies, please refer to our Cookies Policy.
- Device Information: We may gather information about your mobile device, such as hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.
- SMS Data and Emails: Certain Swift Services enable communication between Enterprise Customers and Clients. In facilitating this service, we may receive and collect communication data, including the date and time of SMS messages or emails, phone numbers or email addresses of the parties involved, and the content of the messages or emails.
- Log Information: We collect server logs when you interact with the Services, which may include device IP address, access dates and times, viewed app features or pages, app crashes and other system activities, browser type, and the third-party site or service you accessed before using the Swift Services.
- Other Information You Choose to Provide: We may collect information about your mobile device, including but not limited to, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information. Additional information you directly provide to us, such as when you contact customer support or communicate with us in any other manner, will also be collected.
We may also receive information from other sources and combine that with information we collect through our Swift Services. For example:
- If you choose to link, create, or log in to your Swift account with a payment provider (e.g., Apple Pay) or social media service (e.g. Google), or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app.
- If you also interact with our Services in another role, for instance as an Enterprise Customer, we may combine or associate that information with information we have collected from you in your capacity as a Client.
II. WHERE/HOW DO WE COLLECT PERSONAL INFORMATION
We collect Personal Information about you from:
- You. When you provide such information directly to us, and when Personal Information about you is automatically collected in connection with your use of Swift Services as described in our Cookies Policy.
- Enterprise Customers. When Enterprise Customers upload your Personal Information to our platforms in connection with their use of the Swift Services.
- Third Party Applications. We collect transaction details related to your use of the Swift Services, including but not limited to payment method, purchase amount, date of purchase, description of the goods or services purchased and other related transaction details.
- Advertising Partners. We work with companies that help us deliver, measure and analyze the effectiveness of our ads. These companies collect information about you when you interact with our ads on our platforms and on the websites where our ads are displayed.
- Data Brokers and Information Providers. We may collect information from data brokers and other information providers who may make your Personal Information available to us, as permitted by law.
III. HOW WE USE YOUR PERSONAL INFORMATION
- Our goal is to provide, maintain, and enhance the Swift Services. This includes various activities like facilitating payments, sending receipts, delivering requested products and services along with relevant information, developing new features, offering customer support to Enterprise Customers and Clients, implementing safety features, verifying user identities, and sending updates and administrative messages about our products.
- We carry out internal operations to ensure the smooth functioning of the Swift Services. This involves activities such as preventing fraud and misuse of the services, troubleshooting software bugs and operational issues, conducting data analysis, testing, and research, as well as monitoring and analyzing usage patterns and trends.
- We may enable and facilitate communications between you and Swift, or you and an Enterprise Customer. This can include sending confirmations for appointment cancellations or updates on appointment statuses.
- We may contact you regarding Swift Services, news, events, offers, contests, sweepstakes, or other promotions. Similarly, an Enterprise Customer may use Swift Services to reach out to you for similar marketing purposes. These communications may be in the form of SMS messages, emails, or push notifications on your mobile device, in compliance with applicable laws and any consent requirements.
- We personalize and enhance the Swift Services by providing appointment reminders, suggesting suitable dates and times for appointments, recommending features, content, social connections, referrals, and advertisements.
- We fulfill our legal obligations and protect our legal rights, which may include exercising contractual rights, meeting financial reporting requirements, and complying with court orders, warrants, or subpoenas in accordance with applicable laws.
IV. SHARING OF PERSONAL INFORMATION
In limited situations, we may disclose your Personal Information for the purpose of providing and enhancing the Swift Services, or when mandated by law. If applicable law mandates, we will only share your Personal Information with third parties after obtaining your consent. We may share your Personal Information as follows:
- Among Swift. We may share your Personal Information across Swift businesses and affiliated entities to provide the Swift Services to you, for administrative purposes within Swift or for data centralization and/or logistics purposes.
- Between Clients and Enterprise Customers. As a Client using the Swift Services to interact with an Enterprise Customer, we share your Personal Information with the relevant Enterprise Customer to enable them to perform the services you request. Please note, we are not responsible for the privacy practices of our Enterprise Customers, or their third-party service providers. Please contact the Enterprise Customer you interact with directly for more information on that Enterprise Customer's privacy practices.
- Integrated Partners and Service Providers. We may share your Personal Information with our integrated partners and service providers who provide services for us and our Enterprise Customers as part of delivering or enhancing the Swift Services, such as payment processing services, order fulfillment, website hosting, customer relationship management services, email services, SMS services, auditing, financial services promotions or offerings such as debit card and/or loan services, and other similar partnerships and services.
- Third Party Applications You may choose to share your Personal Information with other third party applications or websites that integrate with our API (e.g. Google, Facebook, etc.) to access certain Swift Services. We may share your Personal Information received from such third party applications with relevant Enterprise Customers from which services you request as well as back to the third party applications from where your Personal Information originated.
- Other Third Parties in Connection with a Corporate Transaction We may disclose or share your Personal Information in the event that we are involved with a purchase, sale, financing, transfer, or acquisition of all or a portion of a business or assets, such as in connection with a merger, or in the event of a bankruptcy reorganization or liquidation.
- Other Parties As Necessary or as Required by Law We may collect information about your mobile device, including but not limited to, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.
V. ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS
VI. LEGAL BASES FOR PROCESSING
We process your Personal Information as follows:
- With your consent (for example, we process data from cookies when you consent to that use and we collect your precise Location Information when you provide consent through your mobile platform);
- When necessary to perform our agreements with you (for example, we use your Transaction Information to confirm and manage your appointments with Enterprise Customers);
- When necessary to ensure compliance with a legal obligation to which we are subject; and
- In the pursuit of our legitimate interests (for example, we use your Account Information to provide our Services)
VII. DATA PROTECTION RIGHTS
Swift values your rights with respect to your Personal Information. In accordance with applicable law, you may be entitled to some or all of the following:
- The right to information: You have the right to request confirmation regarding the storage, usage, and sharing of your Personal Information. You also have the right to be informed about the entities with whom your Personal Information has been shared.
- The right to access: You have the right to request copies of your Personal Information.
- The right to rectification: You have the right to correct or modify any of your Personal Information that you believe to be outdated or incorrect.
- The right to erasure: You have the right to request the deletion of your Personal Information held by Swift, with certain exceptions as specified by applicable law.
- The right to restrict processing: Under specific circumstances outlined by applicable law, you have the right to limit the ways in which we process your Personal Information.
- The right to data portability: In certain situations as specified by applicable law, you have the right to receive copies of your Personal Information in an electronic format and request that we transmit this information to you or another designated third party.
- The right to object to processing or withdraw consent: You have the right to object to the use of your Personal Information by us or withdraw your consent if you have previously provided it.
- The right to avoid automated decision-making: Subject to certain exceptions defined by applicable law, you have the right not to be subjected to decisions based solely on automated processing, including profiling, if such decisions have a significant impact on you legally or otherwise.
VIII. HOW TO EXERCISE YOUR RIGHTS
Swift will comply with an individual's requests, including access, correction, and/or deletion of the Personal Information it stores in accordance with applicable law.
We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.
We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the Personal Information and whether you have an account with us.
You can also designate an authorized agent to make a request on your behalf. If you use an authorized agent, please include written permission that you have designated that agent to make the request, or proof of the agent's power of attorney. We may follow up with you to verify your identity before processing your authorized agent's request.
You may exercise the above rights by emailing us at firstname.lastname@example.org.
In addition, if you are in the European Economic Area or the United Kingdom, you have the right to complain to a data protection authority about our collection and use of your Personal Information. The data protection authority for the UK is the Information Commission's Office - whose website is https://ico.org.uk. Contact information for data protection authorities based in the European Economic Area, Switzerland and certain non-European countries are available on the EU Commission's website via the following link: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
IX. OTHER CHOICES YOU HAVE
You may correct your account information at any time by logging into your online or in-app account. If you wish to cancel your account, please email us at email@example.com. Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated the policies governing the Swift Services, we may seek to resolve the issue before deleting your information.
At times, we or our Enterprise Customers via the Swift Services may send you marketing and promotional information about products and services that may be of interest to you. With respect to marketing communications, you have many choices regarding the use of your Personal Information, as described below:
- Opting Out of SMS Text Messages. Within each marketing related SMS communication, we will provide a means to unsubscribe. You may also opt-out of receiving marketing-related SMS text messages by sending us an email at firstname.lastname@example.org with a note requesting to opt-out. Note, Swift will continue to send transaction-related SMS text messages regarding any products or services purchased while utilizing the Swift Services even after you unsubscribed from marketing-related SMS text messages. Receipt of transactional messages is a condition to using the Swift Services. If you no longer desire to receive transaction-related messages, you must cease using the Swift Services and terminate all accounts with us.
FOR CALIFORNIA RESIDENTS - "Do Not Sell My Personal Information"
We do not sell your Personal Information
X. CALIFORNIA SHINE THE LIGHT DISCLOSURE
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. Swift does not share your Personal Information with third parties for direct marketing purposes unless you provide us with consent to do so.
XII. INTERNATIONAL TRANSFERS OF INFORMATION
We have put in place safeguards to provide adequate protection for transfers of certain information, in accordance with applicable legal requirements. For more information on the appropriate safeguards in place, or to request a copy of these safeguards, please contact us using the contact details listed in the How to Contact Us section below.
XIII. SECURITY, RETENTION, AND STORAGE OF PERSONAL INFORMATION
We use commercially reasonable procedures to protect the information that we collect. However, we cannot guarantee the security of our databases, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet. Swift will keep your Personal Information for seven years. Once this time period has expired, we will delete your data.
XIV. USE OF SERVICES BY MINORS
The Swift Services are not directed or targeted at children under the age of 13 and we request that they do not provide Personal Information through the Swift Services.
We will not discriminate against you for exercising any of your rights with respect to your Personal Information as granted under applicable law. Unless permitted by applicable law, we will not:
- Deny you any goods or services.
- Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
XVII. HOW TO CONTACT US