SWIVEL

Privacy Policy

Please read this notice carefully.

Our Commitment to Privacy 

We at Swivel Transactions LLC, recognize that our relationships with current and prospective customers are based on integrity and trust. We work hard to maintain our customer’s privacy and are very careful to preserve the private nature of our relationship with customers. Simultaneously, the very nature of our business requires that we collect or share certain information about customers with other organizations or companies. Policies and procedures for collecting and disclosing personal information are detailed below: This privacy statement applies to  www.getswivel.io/documents and other technology resources owned and operated by Swivel Transactions LLC, such as mobile applications, web payment portals on this site or on sites operated by other organizations that use such portal, and social platforms, (collectively referred to as the “Services”). This privacy statement describes how Swivel Transactions LLC (“we”, “us”, “our”) collects and uses the personal information you provide through our Services. It also describes the choices available to you regarding our use of your personal information.

Personal Information We Collect

Through our Sites and Apps, subject to your consent if required by law, we may collect the following personal information:

Identifiers (including name and contact information such as telephone number, email address, or postal address)

Information protected against security breaches (such as social security number, financial account information and username and password)

Commercial information (such as your access and purchase history, the products and services we provide to you, your marketing preferences, or information you provide in any communication with us or when you participate in any blog, community or forum on our Sites)

Internet/electronic activity (see “Cookies and Other Tracking Technologies” for additional information)

Professional or employment related information (such as your status with the organization with which you are affiliated or information you provide as a job applicant)

Geolocation

Inferences from the foregoing such as your preferences, characteristics or predispositions

Data anonymization and aggregation. Subject to your consent if required by law, we may anonymize or aggregate your personal information in such a way as to ensure that you are not identified or identifiable from it, in order to use the anonymized or aggregated data. For example, we may use anonymized or aggregated data for statistical analysis including to analyze trends, for product development, and for risk assessments and cost analysis. We may share anonymized or aggregated data with our parent, subsidiaries, affiliates, service providers, or with other third parties.

Sources of Personal Information

We collect personal information from several sources that we use to provide our Services to you, to analyze and improve our Services, and to communicate with you. Those sources include:

Information that you provide to us: We collect personal information that you provide to us when you set up an account with us, use our Services, or communicate with us. For example, if you register for an online account with us, we may request your name, contact information and business information. Providing us with personal information about yourself is voluntary, and you can always choose not to provide certain information, but then you may not be able to take advantage of or participate in some of the Services.

Information collected from third parties: We may collect information about you from third parties in the course of providing our Services to you. For example, we may collect personal information from credit-reporting agencies to enable us to identify you, prevent possible fraud and to deliver the Services to you.

Information collected through technology: When you visit our Sites or Apps (or when you use any of our Services) we may collect certain information about your location, usage, or device through technology such as cookies (see “Cookies and Other Tracking Technologies” for more information). We may collect geolocation in the Apps for the purpose of enabling location-based Services.

How We Use the Personal Information We Collect

Subject to your consent if required by law, we may use your personal information for the following business purposes:

Providing our Services and related support: including to help fulfill your requests for products and Services; to communicate with you about your use of our Services; to respond to your inquiries; to provide troubleshooting and other technical support; and for other customer service and support purposes.

Protecting the integrity of the Services: including to verify your identity; to detect and prevent fraud and unauthorized activities; to facilitate software; to preserve the integrity of the Services and our systems, and prevent unauthorized access and activities; to enforce our applicable terms; and to protect the rights and safety of others.

Analyzing and improving the Services and our business: including to better understand how users access and use our Services; to evaluate and improve the Services and our business operations; to develop new features, offerings and Services; to conduct surveys and other evaluations; and for other research and analytical purposes. 

Personalizing the Services: including to tailor content we send or display on our Sites and Services (e.g., for your geographic area); to offer personalized help and instructions; and to otherwise personalize your experiences with the Services.

Advertising, marketing and promotional purposes: including to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to contact you about our Services, and those of our affiliates, as well as other information we think may interest you. Where required by applicable law, we will obtain your consent to use your personal information for marketing and related purposes.

Securing and protecting our business: including to protect and secure our business operations, assets, services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct.

Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with users or third parties.

Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; to maintain appropriate business records; to enforce company policies and procedures; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.

Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests.

How We Share the Personal Information We Collect

For each category of personal information we collect, we may share such information with the following categories of third parties in the manner and for the purposes described below:

With Swivel Transactions LLC affiliates where such disclosure is necessary to provide you with our Services or to manage our business.

With third-party service providers whose systems, applications, products or services help us to provide the Services. For example, we share personal information with IT service providers who help manage our back office systems or administer our Sites and Apps. These service providers have agreed to confidentiality restrictions and have agreed to use any personal information we share with them, or which they collect on our behalf, for the purpose of providing the contracted service to us.

With our Client with whom you are also engaging when you use the Services. For example, you may be using a Swivel Transactions LLC Site to log into your account with our Client. Swivel Transactions LLC will share the personal information you provide in order to fulfill your request. You may also receive communications from the Client. Each such Client operates independently from Swivel Transactions LLC and their collection and use of your personal information is not subject to this Notice but to their own privacy notices.

With other third parties including financial institutions such as Visa®, MasterCard®, Discover® Card services, and banking institutions involved in supporting, clearing or settling payment-related transactions.

Swivel Transactions LLC may also disclose personal information about you if it believes such disclosure is necessary to comply with laws or respond to lawful requests and legal process, to enforce our agreements, policies and terms of use and to protect or defend the rights, safety or property of Swivel Transactions LLC, users of the Services or any person.

In addition, subject to applicable legal requirements, we may share personal information in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business assets to another company.

We do not sell your personal information to third parties.

Cookies

“Cookies” give users a special, random ID that are small text files, which are stored on the hard drive of a user’s computer. We employ cookies only in our online referral form to recognize you if you are an active client in order to populate this from with your contact information. Use of this cookie eliminates the need for users of this form to type in their contact information each time they use this form. If you are such a client, you may setup your computer to not accept cookies from this Web site; however disabling such feature may prohibit you from using forms.

Managing Your Preferences

Subject to your consent if required by applicable law, we may use your personal information to provide you with informational messages about our products and services as well as those of our global affiliates and third parties. Our informational messaging may be by email, telephone, post or SMS or such other method(s) as may become relevant. In addition, we may provide informational messaging and permit others to do that as allowed by our Clients’ respective contracts.

We will take steps to seek to ensure that any informational messages from us and which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in emails, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.

Changes to this Privacy Policy

Swivel Transactions LLC reserves the right to change this Privacy Policy at any time. Please check this page periodically for changes. Your use of any of our Services, including this website, following the posting of changes to these terms will mean you accept those changes. Our website includes links to other websites whose privacy practices may differ from those of Swivel Transactions LLC. If you submit personally identifiable information to any of those web sites, your information is governed by their privacy statement. We encourage you to carefully read the privacy statement of any web site you visit.

Disclaimer

By using this website, including entering into a credit card transaction, you acknowledge and agree to all the terms in this privacy policy, including that we expressly disclaim any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing or otherwise offering any definitive promise of security in connection with your information, including personal information or usage information, through our payment technology websites.