Privacy
Last revised on July 31, 2023
SWOOVY’S PRIVACY COMMITMENT
Swoovy is committed to your privacy. We design, develop and provide our services and products with privacy and security as key priorities.
Privacy takes a team effort. We work across our company to ensure that your overall experience with Swoovy is private and secure.
Clear communication. We understand how challenging it is in today’s world to get clear information and answers about privacy. Our goal is to keep our communications with you clear and easy to understand with our corporate policies.
PRIVACY POLICY
Our approach to privacy is noted below. We’re focused on making Swoovy a great application for you and utilize different types of data collection, analysis and potentially sharing information with key partners as part of that process.
The effective date of this Privacy Policy is August 27, 2018. EFFECTIVE DATE: August 27, 2018
OUR COMPANY
WHERE THIS PRIVACY POLICY APPLIES
COLLECTING INFORMATION
COOKIES AND SIMILAR DATA COLLECTION TYPES
HOW SWOOVY USES YOUR INFORMATION
SHARING YOUR INFORMATION
YOUR RIGHTS
RESIDENTS OF CALIFORNIA
NOTICE TO END USERS OF CUSTOMERS
RETAINING YOUR INFORMATION
SWOOVY IS FOR ADULTS ONLY
CHILDREN
THIRD-PARTY LINKS
HOW TO CONTACT US
1. OUR COMPANY
The company that is responsible for your information under this Privacy Policy is Swoovy Inc. (“Swoovy,” “us,” or “we”), which is based in Austin, Texas.
2. WHERE THIS PRIVACY POLICY APPLIES
This Privacy Policy applies to websites, apps, events and other services operated by Swoovy. We refer to all of these as our “services” in this Privacy Policy. We will also refer to our Privacy Policy in other Swoovy documentation.
Swoovy also works with different service providers which may have their own privacy policies. In those cases, our data processing agreement with them or their privacy policy applies.
3. COLLECTING INFORMATION
Swoovy is dedicated to helping you make meaningful connections with people as well as nonprofit organizations and their affiliates. We utilize technology to make the whole process much easier and effective. Part of this process is to have you provide us with information so we can customize your experience. We also collect information to continue to improve your experience and our services when you use our application and participate in events. We have more details about our approach in this agreement.
Information you share with Swoovy
We ask for information to provide the services and enhance your user experience including but not limited to:
o Basic information about you (gender, age, city, etc.).
o Contact information such as your email address and phone number, and employment status.
o Account information such as your user credentials or information for SSO (single sign on).
o Over time we may request additional information from you to continue to customize and improve your experience with Swoovy. This can include things like photos, videos, interests, your personality, and your lifestyle. You consent to providing us with this information when you provide it to us.
o Any time you subscribe to a paid service or make a purchase from Swoovy (rather than services based on iOS or Android), you will provide Swoovy or our payment service provider with the payment details needed to complete the purchase.
o We may conduct contests, promotions, surveys and other activities where we solicit your feedback and capture registration information.
o We also capture information when you communicate with our company and customer service to improve our products and services as well as train our team.
o We may also capture information about other people you may discuss with us as part of customer service or correspondence, chats with users, and other content.
Information from other people
We also receive information about you from others which includes:
o Swoovy Users
Other users may provide information about you when they use our application and other services. We may collect information about you from other users if the contact us about you. It can also happen when a user has us access her/his phonebook contacts and you are one of them. We may use it to reach out to you in accordance with their instructions.
o Swoovy Partners
We may receive information about you from our partners, including nonprofits we team with to provide volunteering services or other organizations seeking volunteers (each, an "Agency"). For example, you will in some instances be able to create a Swoovy account from an Agency’s website (in which case they pass along registration information to us). In addition, in some instances Swoovy ads are published on an Agency’s website and platform (in which case they may pass along details to us).
You may have accessed Swoovy by visiting our website or through the site of one of our Agencies or affiliate partners. This notice applies to all information you submit to Swoovy through either of these types of sites. Please note that we cannot be responsible for the information you submit directly to third parties, including our Agencies or affiliate partners, who may have their own posted policies regarding the collection, use, and disclosure of your information. We urge you to review the policies of our Agencies or affiliate partners through whom you may access our services.
We will forward your information to Agencies when you indicate to Swoovy you are interested in a specific volunteer opportunity and you provide us with your information. This helps the Agency to contact you or connect you with a local affiliate. Each Agency has specific policies regarding collection and use of personal information. We are not responsible for their use of your information. Please contact the Agency directly using the contact information posted for that Agency on their website.
When you provide information to us through our services regarding volunteer opportunities associated with one of our Agencies, or have accessed the services through an Agency, we may share your information and connection history with the applicable Agency. Our Agencies each have their own policies regarding the collection and use of personal information, and Swoovy is not responsible for their use of your information. Furthermore, our Agencies may collect additional information from you, independent of Swoovy, in connection with the volunteer services.
o Swoovy Service Providers
Third party vendors may collect information on our behalf as necessary to provide services to Swoovy. To learn more about our service providers, please read Section 6 (Sharing Your Information).
Information we collect
When using our services, we collect details about which features you’ve used, the ways you’ve used them, and devices used to access them. We may collect this information directly through our systems or indirectly through a service provider. Details include:
o Usage Information
We collect information when you use our services (e.g., date and time logged in, features accessed, searches, clicks and pages which have been shown to you, referring webpages, ads you click on) and interactions with other users (e.g., specific users, time and date, number of messages exchanged) as well as other information necessary to provide the services, which may or may not be personal data.
o Device Information
We collect information from and about the device(s) and software you use to access our services, including:
o IP address, device ID and type, device-specific and apps settings and attributes, app crashes, ad IDs (including Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
o Wireless and mobile network connection, including service provider and signal strength; and o Device sensor data including compasses, gyroscopes and accelerometers.
o Additional Information Based on Your Approval
By providing us with permission, we can collect your precise geolocation (latitude and longitude, depending on the device and service and you’re using, including Wi-Fi connections, Bluetooth and GPS). Your geolocation information may be collected in the background even when you aren’t using the services
if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.
We may collect (with your permission) your photos and videos (to publish a photo, etc.).
o Information You Choose to Provide
We may collect additional information which you choose to provide, such as when you register for an event, when we correspond with you as a customer, when you participate in a survey, or when you contact us for help.
4. COOKIES AND SIMILAR DATA COLLECTION TYPES
Use of Cookies
We use may use cookies in our service to personalize your experience. A cookie is a small text file that is placed on your device by a webpage server. Cookies cannot be used to run programs or deliver viruses to your device. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. One of the primary benefits of cookies is to save you time and effort. A cookie can utilize your page visits, navigation, etc., to help the site to recall your specific information on subsequent visits. This informs the delivery of relevant content, improves site navigation, etc. When you return to the website, the information you previously provided can be retrieved, enabling the features you personalized. Swoovy may occasionally share aggregated site statistics with partner companies. You can accept or decline cookies. Most web browsers permit you to decline cookies if you want. By choosing to decline cookies, you may not be able to fully experience the features of this or other websites.
Webpages on our website may contain electronic images known as web beacons - sometimes also called single-pixel gifs - that allow our website to count users who have visited those pages and to deliver co-branded services. Our website may include web beacons in promotional e-mail messages or newsletters in order to determine whether messages have been opened and acted upon. Some of these web beacons may be placed by third-party service providers to help determine the effectiveness of our advertising campaigns or email communications. These web beacons may be used by these service providers to place a persistent cookie on your device. Doing this allows the service provider to recognize your device each time you visit certain pages or emails and compile anonymous information in relation to those page views.
Certain web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Swoovy, do not currently respond to DNT signals, except to the extent required by applicable law.
Cookies of Third Party Providers and Tracking
With your permission, our website, desktop and mobile application utilizes the Conversion Tracking Pixel service of Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA (“Facebook”). This tool allows us to follow the actions of users after they have redirected to a provider’s application or website by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remain anonymous. This means that we cannot see the personal data of any individual user. However, the collected data are saved and processed by Facebook. We are informing you on this matter according to our information at this time. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with Facebook’s Data Use Policy found under: https://www.facebook.com/about/privacy/. Facebook Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside Facebook. In addition, a cookie will be saved onto your computer for these purposes.
Only users over 13 years of age may give their permission. Please click here if you would like to revoke your permission: https://www.facebook.com/ads/website_custom_audiences/.
5. HOW SWOOVY USES YOUR INFORMATION
We primarily use your information to deliver and improve our services. We may also use your information for safety purposes for you as well as customized ads. Here are more details.
Account administration and services
o Create and manage your account
o Provide customer support
o Complete your transactions
o Communicate about our services, including order management and billing
o Undertaking security, quality, or safety activities
o Processing your financial information
o Managing our business
o Allowing you to register for events
Help connect you with other users
o Analyze your profile and those of others to recommend meaningful connections
o Enable you to register for philanthropic activities
o Show users’ profiles to one another
o Video chat and voice chat
Ensure a consistent experience across your devices
o Link the various devices you use so that you can enjoy a consistent Swoovy experience on all of them. We do this by linking device and browser data including things like IP address, browser details and other data.
Serve you relevant ads and other offers
o Discounts, contests, events and other offers
o Develop, display and track content and advertising tailored to your interests on our services and other sites
o Communicate with you by email, mobile device, social media or phone about products or services that we think may interest you
Improve Swoovy services and create new ones o Administer surveys, focus groups and other activities
o Research and analyze user behavior and interests to improve our services and content oDevelop new features and services
o Develop new features and services
o Research for technological deleopment
o Identifying and repairing errors to existing functionality
o Provide you with additional content and tailored services
To prevent, detect and fight other illegal or unauthorized activities including fraud
o Address ongoing or alleged misbehavior on and off-platform
o Perform data analysis to better understand and design countermeasures against these activities o Retain data related to fraudulent activities to prevent against recurrences
o Retain data related to fraudulent activities to prevent against recurrences
To ensure legal compliance
o Comply with legal requirements
o Assist law enforcement
o Enforce or exercise our rights, for example our Terms of Use
To perform other functions you consent to or that are otherwise described to you at the time of collection.
To process your information as described above, we rely on the following:
o Provide services to you according to contract: We typically process your information to honor our agreement(s) with you.
o Legitimate Interest, such as improving our services: We may use your information where we have legal and legitimate interests to so to improve our features, add new ones, detect and prevent fraud, etc.
o Consent: Swoovy may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.
6. SHARING YOUR INFORMATION
Our goal is to help you make meaningful connections between our users which requires sharing user information with other users. We also share some users’ information with service providers and partners who assist us in operating the services, and, in some cases, legal authorities. Additional details include:
o Sharing with other users
Given that you are sharing some personal information in a public forum, we recommend that you keep in mind your information being viewable by others. We cannot control what other people do with your information once you share it publicly.
o Sharing with our service providers and partners
We use third parties to help us operate and improve our services. These third parties may assist us in a variety of areas including analytics, product development, payment processing, security, data hosting, legal, etc.
We also may share information with organizations that assist us in with advertising and social media activities. This may include sharing very limited information on you in hashed, non-human readable form to our partners.
We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.
o Corporate transactions
We may transfer your information in conjunction with potential activities including a sale, merger, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
o Required by law
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
o Enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
o By your consent or request
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in Section 4 above entitled “Cookies and Similar Data Collection Types.”
7. YOUR RIGHTS
We want you to be in control of your information and provide you with tools, including:
o User settings. Features available for you to access, change, or delete information that you provided to us associated with your account directly within the service. Please feel free contact our customer care team for assistance via email at: teamswoovy@swoovy.com
o Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either approve or deny the collection of the related information or display of the related notifications. These decisions will affect the functionality you can access.
o Deletion. You can delete your account by using the corresponding functionality directly on the service.
We want you to be aware of your privacy rights. Here are a few key points to remember:
o Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by sending us an email at: teamswoovy@swoovy.com
o Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us via email at: teamswoovy@swoovy.com
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact Swoovy’s Privacy Officer to provide their written consent before the information is released.
o Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
Depending on where you reside, you may have the right to exercise additional rights available to you under applicable laws, including EU:
o Right of erasure. You may have a broader right to erasure of personal data that we hold about you. For example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record-keeping purposes, to complete transactions, or to comply with our legal obligations, among other things.
o Right to object to processing. You may have the right to request that we stop processing your personal data, including the right to opt in or opt out of the sale of your Personal Data to third parties, or to stop sending you marketing communications.
o Right to restrict processing. You may have the right to request that we restrict processing of your personal data in certain circumstances. For example, where you believe that the personal data we hold about you is inaccurate or unlawfully held.
o Right to data portability: In certain circumstances, you may have the right to be provided with your personal data in a structured, machine-readable, and commonly used format and to request that we transfer the personal data to another data controller without hindrance.
If you would like to exercise any of the above rights, please contact us using the information available below. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of EU Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. You may also have the right to make a complaint to other regulators. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
You may have other rights to request access to, correct, delete, or restrict processing of, some or all of the information that Swoovy has on you in certain US states, or by contract with a relevant organization in those states. This may include the right to limit use and disclosure of sensitive personal information, and the right to non-discrimination for exercising your rights.
You may also have the right to opt out of some processing due to state laws such as certain advertising data sharing (i.e., targeted advertising or cross contextual behavioral advertising), profiling, or email marketing (except for transactional correspondence). Alternatively, you may have the ability to delete and disable cookies, and other tracking/recording tools (to learn more about cookies, clear gifs/web beacons and related technologies, you may wish to visit http://www.allaboutcookies.org and/or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org).
Your state law rights may be subject to certain limitations and conditions. We may be restricted from acting in certain cases, such as if we are not the controller (the organization with legal responsibility for making decisions) of your information.
If you need further assistance regarding any of your rights, wish to exercise a right or receive a disclosure provided by law that is not listed here, or to attempt to resolve a privacy issue prior to contacting regulators, please contact us using the contact information provided below.
8. RESIDENTS OF CALIFORNIA
We are not a “business” under the California Consumer Privacy Act (CCPA), however, we have determined that we may collect and use the following categories of personal data (from the CCPA) about consumers for a business purpose as a service provider where a customer is a “business” under the CCPA.
o Category A: Identifiers;
o Category B: Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
o Category C: Protected classification characteristics under California or federal law (if you choose to provide);
o Category D: Commercial information;
o Category F: Internet or other electronic network activity;
o Category G: Geolocation data;
o Category I: Professional or employment-related information;
o Category K: Inferences drawn from other Personal Data to create a profile about a consumer.
We have not sold consumers’ personal information in the preceding 12 months.
If you need assistance with this privacy policy due to a disability, please contact us at the contact information available below.
If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request via email to: teamswoovy@swoovy.com
Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity and California residency before we can answer such a request.
To exercise your rights under the CCPA, please see “Notice to End Users of Customers” below and the “Your Rights” section above.
9. NOTICE TO END USERS OF CUSTOMERS
Some of our services are intended for use by organizations. Where the services are made available to you through an organization, that organization is the administrator of the services and is responsible for the accounts and/or service over which it has control. Please direct your data privacy questions to your administrator, as your use of the services is subject to that organization's policies and our agreement with the organization. We are not responsible for the privacy or security practices of an administrator's organization, which may be different from this policy.
Administrators may be able to:
o help you exercise your privacy rights;
o allow you to reset your account password;
o restrict, suspend or terminate your access to the services;
o access information in and about your account;
o access or retain information stored as part of your account;
o change your information, including profile information associated with your account; and
o allow you or restrict your ability to edit, restrict, modify or delete information.
Please contact your organization or refer to your administrator’s organizational policies for more information.
10. PROTECTING YOUR INFORMATION
Our goal is to protect you from unauthorized access to or any disclosures, alterations or destruction of your personal data. We will continue to take steps to secure your data but cannot promise, nor should you expect, that your personal information will always stay secure.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify Swoovy immediately via email to: teamswoovy@swoovy.com.
11. RETAINING YOUR INFORMATION
We keep your personal information only as long as we need it for legitimate business reasons and as protected by law.
We will delete or anonymize your information upon deletion of your account, unless:
we must keep it to comply with applicable law;
we must keep it to evidence our compliance with applicable law;
there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.
Swoovy cannot promise that all data will be deleted within a specific timeframe if due to technical constraints.
12. CHILDREN
Swoovy does not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. Please inform Swoovy if you suspect a user is under the age of 18. Nonprofits may accept volunteers that are younger than 18, review their regulations and registration policies directly.
13. PRIVACY POLICY UPDATES
Swoovy’s Privacy Policy may change. We will notify you before any material changes take effect so that you have time to review the changes.
14. THIRD-PARTY LINKS
Our service contains links to other third-party sites. Swoovy is not responsible for the privacy practices or the content of such third-party sites.
15. OPT-OUT
Swoovy provides users the opportunity to opt-out of receiving communications from Swoovy. To opt-out, you can (1) utilize the provided mechanism (such as by replying STOP to a text message, or the opt-out link on an email); or (ii) email teamswoovy@swoovy.com. Certain necessary transactional messages may continue even if you opt out.
16. HOW TO CONTACT US
If you have questions about this Privacy Policy, please email us at: teamswoovy@swoovy.com