Privacy Policy

Which Websites Does this Online Privacy Notice Cover? 

This Online Privacy Notice applies to the information practices of Swrve’s websites www.swrve.comwww.converser.io, dashboard.swrve.com and eu-dashboard.swrve.com

Swrve websites may provide links to websites operated by third parties. Third party websites are not covered by this policy. We encourage you to review the privacy policies posted on any such third party websites.  The inclusion of a link to a third party website does not imply an endorsement of the linked site or service by Swrve.

What Kinds of Information Does Swrve Collect?

Swrve collects Personal Information from individuals who visit our public website, and use our platform.  We may supplement such data with data collected from third parties (including other companies, such as advertising networks, analytics providers, and search information providers).

  • Personal Information: For the purposes of this policy “Personal Information” means any information or data that is or can be used to identify a person, either alone or in conjunction with other information that is in, or is likely to come into our possession. 
  • Contact Information: You may voluntarily provide Personal Information, such as contact information, or we may ask for such information in various forms on our website or platform, including requests for product or service information, white papers, registration for webinars, and the like. 
  • Transactional Data: When you access our website, our platform or use our service some information may be automatically collected and stored, 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.   
  • Cookies: We also collect certain Personal Information through the use cookies, log files and similar technologies.  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.  Swrve’s cookie policy for its website can be found here Cookie Notice and the cookie notice for our platform is available in the legal section on our platform.
  • Business Contacts: Swrve may also collect basic contact details from business contacts (e.g., customers, potential customers and website visitors) and other related Personal Information that may be entered into our website, or platform in the course of providing our service (“Business Contacts”). 
  • Billing Information: When purchasing our services via our website, we may also require Business Contacts to provide us with financial qualification and billing information, such as billing name and address or credit card number.   
  • Sensitive Information: Swrve does not collect or process “sensitive information” (i.e., information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of an individual) through its website or platform.

How Does Swrve Collect My Personal Information?

Swrve may collect information from you in a variety of ways, including:

  • Through Your Web Browser or Device:  Most browsers and devices collect certain demographic data automatically, for example, type and version of operating system, screen resolution, device manufacturer and model, language, Internet browser type and version, etc.  This data does not contain any information that can identify you personally and is used to evaluate and improve our website and services.
  • Through Cookies and Similar Technologies: We use cookies to make our websites and platform operate more efficiently, to improve our services, to provide analytic information, and to personalize your experience.  For more information about how we use cookies, please see our Cookie Notice
  • IP Address: IP addresses are automatically transmitted as part of any Internet communication, and collecting IP addresses is a common practice; many websites, applications and other services collect IP addresses automatically.  We use IP addresses for purposes such as calculating usage levels of certain services, helping diagnose server problems, security, and administering the Swrve services.
  • Through Your Use of our Platform and Services: The Swrve platform may transmit data in order to validate users or take other measures to prevent unauthorized use, check for updates and provide error, demographic, and usage statistics to Swrve.  

How Does Swrve Use Personal Information it Collects?

Swrve will only use your Personal Information for the purpose it was collected or to perform the services requested, including without limitation, to do the following:

  • to deliver information and/or a product or service that you have requested; 
  • to personalize your experience, for example we may ask your preferences in relation to device information, app type, or platforms and use that information to tailor our communications to you;
  • to send you marketing communications you have requested or that we believe may be of interest to you, such as newsletters and information on product updates;
  • to provide you with customer service regarding Swrve platform and services you may have licensed from us;
  • to respond to technical support and other enquiries;
  • for our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, testing, enhancing, improving, or modifying our services, identifying usage trends, determining effectiveness of our promotional campaigns and expanding our business activities; and
  • to send administrative information to you, for example, information regarding Swrve services and changes to our terms, conditions, and policies; and
  • as described to you when we collect the information.

We may combine this information with information you give to us and information we collect or receive from third parties about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

We will not use your Personal Information for a purpose that is materially different from the purpose(s) for which it was collected, without first asking your permission and giving you an opportunity to “opt-out” of such use. 

Swrve may from time to time post customer testimonials or case studies on its website that contain information such as names and titles. Prior to posting any such information or posting testimonials, we obtain the consent of the customer.

Does Swrve Share My Personal Information?

We may share your Personal Information with certain third parties for processing, storage, or fulfilment (“Authorized Third Parties”), including the following:

  • Swrve Group Companies: affiliated companies (including with their respective employees and contractors) within the Swrve group worldwide for the purposes described in this policy.
  • Service Providers: third-party service providers and suppliers who provide services to us such as website hosting or administration, data hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing (if applicable), auditing, database services (such as Salesforce.com), and other similar services;
  • Business Partners: our business partners or for product development, marketing or public relations purposes. In such cases the information shared is, where possible or appropriate, limited to aggregated or anonymized data and will not include any Personal Information.
  • Change of Control: In connection with a merger, sale, joint venture, assignment, acquisition, financing, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any reorganization, bankruptcy or similar proceedings).  In such event, any acquiring company will be required to assume the rights and obligations of Swrve described in this privacy policy;   
  • Compelled Disclosure:  In addition to the foregoing, we may also share your Personal Information as we believe is required, necessary, or appropriate, including the following:
    • under applicable law, including laws outside your country of residence; 
    • to comply with legal process and/or to respond to verified requests to meet law enforcement or national security requirements, or from immigration, customs or other competent public and government authorities, including public and government authorities that may be outside your country of residence relating to a criminal investigation or alleged illegal activity; 
    • to enforce our terms and conditions; 
    • to protect our operations and those of any of our group companies; 
    • to protect our rights, privacy, safety and physical and intellectual property, and/or that of our affiliates, you or others; and
    • to allow us to pursue available remedies or limit the damages that we may sustain.

We only provide Authorized Third Parties with the minimum amount of Personal Information necessary to complete the requested service. We do not, nor do we allow third parties, to use Personal Information we collect for a different purpose, without providing you with notice and an opportunity to opt out. Authorized Third Parties are required to keep all Personal Information private and secure and ensure that they have adequate controls and protections in place with regard to such Personal Information.  Other than as outlined above, we do not sell or otherwise make your Personal Information available to third parties.  

How Do I Update My Personal Information or Communication Preferences?

You have a right of access to any personal information we hold about you.  We do not maintain online profiles, however you may contact us at any time to access, delete, edit or correct any Personal Information you have provided to us, by contacting your Swrve sales rep or emailing us at privacy@swrve.com. We may require proof of your identity, but we will request this where required. We will respond to you within 45 days of your request.

You can opt out of  marketing communications by following the unsubscribe instructions in the communication (for example click the unsubscribe link, or respond to the message with the word “Unsubscribe”). However, we reserve the right to send a message confirming your opt out whether it applies to email, sms messages or other formats; and we may still send you administrative, relationship, or transactional messages (for example, we might send a notice about changes to our Terms of Service or changes to the functionality of a product or service).

Alternatively you may make a written request by sending a letter to one of the mailing addresses in the How Can I Contact Swrve? section below including your name, user ID (if applicable), e-mail address, and the details of your request. For example, if you wish to unsubscribe from a newsletter, include the name of the newsletter.

How Does Swrve Keep my Personal Information Secure?

The security of your personal information is very important to us.  We take all reasonable and appropriate measures to guard against accidental, unauthorized or unlawful loss, access, disclosure, alteration, or destruction of your Personal Information, taking into account the risks involved in the processing and the nature of the Personal Information. We use industry-standard security measures to protect the integrity and confidentiality of any Personal Information we own or process on behalf of our customers and visitors, including, in appropriate circumstances, the use of firewalls, restricted access and encrypted transmissions. We limit access to Personal Information to those persons in our organization who have a business need to process such Personal Information. Additionally, Swrve requires any sub-processers that it may use to adhere to the foregoing security measures.

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  Although we will do our best to protect your Personal Information, any transmission is at your own risk and we cannot guarantee the security of your data transmitted to our site.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us of the problem by contacting by any means set out in the How Can I Contact Swrve? section below.

If you have created an account with us, you are responsible for keeping your account details confidential.  We will not ask you for your password, except when you log in to our platform. If any breach of security is suspected, in order to protect you and your information, Swrve may suspend your use of a website, without notice, pending an investigation. 

How Does the Swrve Service Use My Personal Information?

The Swrve Service may be used by Swrve customers without providing Swrve with any Personal Information regarding end users of its applications (the “End User PII”).  However, in the event a Swrve customer wants to personalize the experience of the end users of its applications using the Swrve Service or use certain features, some End User PII may be processed through the Swrve Service.  End User PII is collected directly by the Swrve customer, not by Swrve, and therefore is controlled by the customer’s privacy policy, including the ways in which a Swrve customer may use End User PII on our platform.  In such cases, Swrve processes End User PII according to the limited and specified purpose of fulfilling instructions of its customers (as a Data Processor).  Swrve does not control a customer’s use of its End User PII, and is not responsible for the behavior of its customers.  We do not review, comment upon, or monitor our customers’ 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.  However, in the event we determine that we cannot process End User PII according to the appropriate level of protection, we will notify the customer and stop processing such End User PII.

How Long Will Swrve Retain My Personal Information? 

Swrve will only retain your Personal Information to fulfil the purposes for which it was collected or as required by applicable laws or regulations.

How Does Swrve Treat EU Personal Information?

Swrve endeavours to treat all Personal Information to the highest principles.  Residents of the European Economic Area may be entitled additional rights or protections.  Please see our EU-US Privacy Shield Notice here.  

Does Swrve Collect Personal Information from Children?

Swrve products and services are not directed at minors, and Swrve does not market its website, platform or services to children under the age of 13.  We do not knowingly solicit or collect the Personal Information of children under the age of 13 or minors as otherwise defined in local law or regulation.  We request that minors do not provide Personal Information to Swrve.  However, if you have reason to believe that we may have collected Personal Information of a minor, please contact us at privacy@svrve.com or let us know by any means set out in the How Can I Contact Swrve? section below.  If we learn that we have collected children's Personal Information without appropriate parental consent, we will promptly delete it from our systems.

What If I Am Submitting Information In Connection With An Employment Opportunity?

If you submit Personal Information to Swrve in connection with an employment opportunity, Swrve will only use such Personal Information for recruitment purposes, and if you are offered a job or become employed by Swrve, for other employment-related purposes.

By submitting your resume/C.V. information to Swrve, you agree that we may use it for recruitment purposes (including transferring the data to other countries, transferring your information to other companies authorized to perform specific services for Swrve and/or other processing relevant to recruitment purposes).  It will not be shared with others for non-recruitment purposes.

Resumes/C.V.s should include information relevant to your employment history and education (degrees obtained, places worked, positions held, relevant awards, and so forth). Swrve recommends that you do not disclose sensitive personal characteristics (e.g. gender, height, weight, religion, philosophical or political beliefs, financial data) in your resume/C.V. or letters to Swrve.

Swrve will not retain your Personal Information longer than is necessary for the purposes for which it is collected.  Resumes/C.V.s may be retained in order to comply with various country requirements on applicant data reporting.

If you need to update or otherwise make changes to your resume/C.V., simply resubmit a new resume/C.V. If you wish to have your resume/C.V. completely removed from our system, please send an email to privacy@swrve.com. To aid our team in locating your resume/C.V., please be sure and include your name, email address and phone number as submitted with your resume/C.V.

By submitting your resume/C.V., you are consenting to the export of your information to the country where the job opening is located and to the United States (for certain employment related data) for processing and storage.

How Will I be Advised of Updates to this Policy?

You should check www.swrve.com/privacy or www.converser.io/privacy (as applicable) for updates.  However, for major changes to this policy in the future, Swrve will provide a notice on our website prior to implementing the change.  Should a change involve a material new use of information, Swrve will also provide those affected with a prior and meaningful opportunity to opt out of that new use.

For information on your rights contact your national data protection supervisory authority.  In the EU visit http://ec.europa.eu/justice/data-protection/ or in the United States visit www.commerce.gov or www.ftc.gov.

How Can I Contact Swrve?

You can contact Swrve at privacy@swrve.com, via the contact form or other email addresses provided on our website, or by post at the one of the addresses listed below. Please include your contact information, name of the Swrve website or service, and a detailed description of your request or privacy concern.

Swrve New Media Inc.
ATTN: Privacy
55 Stockton Street, Suite 400
San Francisco, CA 94108
USA

New Game Technologies Ltd. t/a Swrve New Media
ATTN: Privacy
One Stephan Street 
Dublin 8, Ireland
Registration No. 449422

California Residents: California Civil Code Section 1798.83 permits customers of Swrve who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.  Requests can be sent to Swrve as described above.

Last updated: January 10, 2017