Privacy Policy

Updated: October 2015

Swrve (“us”, “we” or “our”) has drafted this Privacy Statement to explain how we use data you provide to us through our website (“Website”), our platform (“Platform”) or our service (“Service”).

Our Privacy Statement will be updated from time to time. Should our privacy practices change, we will post the policy changes on our Website or Platform and indicate the date the Privacy Statement was last updated. We encourage you to check back at our Website or Platform periodically if you are concerned about how your information is used. All changes will take effect 30 days after they are initially posted on our Website or Platform unless you are a new user, in which case they take effect immediately.

1. Information We Collect

You can visit and browse our Website without providing any information about yourself. You may voluntarily provide personal information, such as contact information, or we may ask for such information in various forms on our Website, including requests for product or service information, white papers, registration for webinars, etc. Where you do provide personal or contact information, you may not provide false information about yourself.

When you access our Website, our Platform or use our Service some information may be automatically collected, such as your computer's or mobile device’s Internet Protocol (IP) address, your computer's or mobile device’s operating system, the browser type, the address of a referring web site, and the time and date of your visit. Please refer to the cookie policy relevant to your use of the Website or Platform for further information. As we use different cookies on our Website and our Platform, each has a separate cookie policy.

We may use your email address or other contact information you give us to contact you with product or service information. If we ask for your preferences (e.g. in relation to device information, app type, platforms), we will only use that information to tailor our communications to you. We may also use your preference information on an aggregated basis (where you are not personally identifiable) for our business, research, product development and marketing purposes. Other than as outlined below, we do not make personally identifiable information relating to living individuals (“Personal Data”) available to any third party and we do not sell any Personal Data to third parties.

Swrve representatives may also collect Personal Data from representatives of customers and potential customers on Swrve’s behalf in the course of providing our Service. This consists primarily of information such as basic customer contact details you might enter onto our Website or Platform (“Customer Information”).

We are responsible for the use and processing of Customer Information collected through our Website or Platform as a “Data Controller”, and we own this data.

Where you subscribe to our Service, in addition to the information collected above, we may serve as a “Data Processor”, on your behalf, with respect to data related to your customers (“End Users”). Some of this data may include Personal Data. We are not the Data Controller for End User data.

Please see our terms of service for more information on how we process End User Personal Data.

2. When Swrve discloses personal data

We ask you to take note that when you use our Website, your data may be sent to the United States and other countries.

Because we operate globally, we may share your information with other Swrve affiliates and business units in other parts of the world in order to provide you with our Service. We may transfer your Personal Data from your home country to our employees in our offices around the world, which may communicate with you regarding your inquiry. Please understand that we limit access to your Personal Data to only those Swrve employees who we believe need access in order to provide our Service to you or to otherwise do their jobs.

With respect to Customer Information, if you are located in the European Economic Area (“EEA), to regulate the transfer of this data to our US entities, we have put in place the EU Commission standard contractual clauses for the transfer of personal data from the community to third countries..

We may also share data, including Personal Data, with our business partners or subcontractors. In the limited instances where third parties outside the EEA process Personal Data on our behalf, we require these companies to sign up to “Safe Harbor” or otherwise satisfy the EU requirements to ensure that the Personal Data is given adequate protection.

In addition to the other purposes outlined in this policy, we may share:

  • Any information or data in response to a verified request by law enforcement, immigration, customs or other government officials relating to a criminal investigation or alleged illegal activity. This Privacy Statement does not apply to the extent that it is in conflict with any law that may be applicable to your Personal Data.
  • Information or data with our business partners or for product development, marketing or public relations. The information shared is limited to aggregated or anonymized data.
  • Any information or data with our hosting provider who may only use the information to administer our Website or Platform. The hosting provider is required to keep all information private and secure.
  • Any information in connection with any merger, sale of Swrve’s assets, or a financing or acquisition of all or a portion of our business by another entity. If another company acquires Swrve or its assets, that company will assume the rights and obligations regarding such Personal Data described in this Privacy Policy.

3. Opt-out

We provide you the opportunity to 'opt-out' of having your Personal Data used for certain purposes, when we ask for this information. For example, if you register with us but no longer wish to receive our newsletters or related communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at privacy@swrve.com.

4. Security

We take appropriate technical and organizational measures to guard against unauthorized or unlawful processing of your Personal Data and against accidental loss or destruction of, or damage to, your Personal Data. We use industry-standard security measures to protect the integrity and confidentiality of any Personal Data we own or process on behalf of our customers, including, in appropriate circumstances, the use of firewalls, restricted access and encrypted transmissions. We limit access to Personal Data to those persons in our organization who have a business need to process such Personal Data. No company, however, including ours, can fully eliminate the security risks associated with such Personal Data.

5. How to edit, delete and access your information

You may ask us to edit or correct any Personal Data you have provided directly to us at any time. You have a right of access to any personal information we hold about you. Where you wish to access the information held about you, please email privacy@swrve.com. We may require proof of your identity, but we will request this where required. We have a legal obligation to respond to you within 40 days of your request.

6. Access to persons under 13 years

Our Website is not intended for persons under 13 years of age. It is not developed or directed at children. We do not knowingly solicit or collect any personally identifiable information from children under the age of 13, nor do we knowingly market our Website, Platform or Service to children under the age of 13. If we learn that we have collected personal information from a child under the age of 13 contrary to local laws, we will delete that information as soon as possible. Please contact us at privacy@swrve.com if you have reason to believe that any personal information from or about a child under 13 has been provided to us without the appropriate consent.

7. Third parties

Please be advised this Privacy Policy does not apply to the practices of companies that we do not own or control, or to people that we do not employ or manage. This includes links to other websites on our Website or Platform as well as any companies from whom you may have ordered services or products that are transmitted over our network, and any companies from whom you may be purchasing services. We recommend that you be aware when you leave our Website or Platform and read the terms of use and privacy policies of any site, product or service that collects Personal Data.

8. Disclaimer

We cannot ensure that all of your private communications and other Personal Data will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), we may be forced to disclose Personal Data to a government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your Personal Data that they collect from the Site. We do not review, comment upon or monitor our customer’s compliance with their respective privacy policies, nor do we review customer instructions to determine whether they are in compliance or conflict with the terms of a customer’s published privacy policy.

9. Contact us

If you have any questions about or suggestions to improve this privacy statement or our information practices you can contact us by emailing us at privacy@swrve.com.

This document was last updated on October 2015.

Swrve is - 

In the US

Swrve New Media Inc,
575 Market St, Ste 2725,
San Francisco, CA 94105, USA

In the rest of the world

New Game Technologies Limited t/a Swrve,
2nd Floor, IBOA House,
Stephen St Upper, Dublin 8, Ireland

Company Registration Number: 449422