Privacy Shield

Swrve New Media Inc., (“Swrve”) is committed to the privacy principles set out in the EU-US Privacy Shield Framework (the “Principles”) and to treating all Personal Information received from residents of the European Economic Area (“EEA”) according to those Principles.  

Privacy Shield Registration: Swrve is not yet registered under the Privacy Shield Framework, but is working to become Privacy Shield compliant.  

FTC Investigation and Enforcement: If/when Swrve is registered under the Privacy Shield Framework, Swrve will be subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.  Swrve also is committed to cooperating with EEA data protection authorities.

Scope: This EU-US Privacy Notice is supplemental to and part of Swrve’s Online Privacy Notice at www.swrve.com/privacy-policy, (the “Privacy Notice”) and applies to Personal Information received from the EEA for which Swrve is the Data Controller or Data Processor.  Swrve will comply with the Principles in respect of such Personal Information.  If there is any conflict between the terms in our privacy policy, this EU-US Privacy Shield Notice and the Principles, the Principles shall govern.  For more information on Privacy Shield visit www.privacyshield.gov.  

Data Controller: the “Data Controller” for data collected by us through our website or platform is Swrve New Media Inc., in the US and New Game Technologies Ltd., t/a Swrve New Media in the rest of the world.

Data Processor: Where our customers subscribe to our service, we serve as “Data Processor” on their behalf for their end user data, which may contain Personal Information, but we do not control such data.  Please see the Term of Service on our website for more information on who we process end user Personal Information.  

Standard Contractual Clauses:  In addition to our efforts to become complaint with the Principles, we have put in place the EU Commission Standard Contractual Clauses to permit the transfer of Personal Information from the EEA to third countries to regulate the transfer of Personal Information to Swrve US entities.

Disclosure to Third Parties: In addition to the information set out in our Privacy Notice regarding disclosure of Personal Information to Authorized Third Parties, if you are located in the EEA, the following will apply:

  • Authorized Third Parties who may access, process or store your Personal Information in the course of performing their services, as described in the Privacy Notice, may be located outside your country of residence, unless otherwise required by law. 
  • Consequently, you acknowledge that your use of the website or platform may involve the transfer, storage and processing of your Personal Information to and in various countries around the world that may have different levels of privacy protection than your country.  By submitting your Personal Information to us, you consent to this transfer, storing or processing.  In addition, where required by the laws of the European Union, Swrve takes steps to ensure that an adequate level of protection is in place for such transfers.
  • Swrve maintains contracts with these Authorized Third Parties (other than in the case of compelled disclosure set out in the Privacy Notice) restricting their access, use, and disclosure of Personal Information, and we may be liable if they fail to meet these obligations, unless Swrve proves that it is not responsible for the event giving rise to the damage.   

Inquiries and Complaints: You may direct any inquires or complaints regarding our handling of your Personal Information to privacy@swrve.com.  Swrve will respond within forty-five (45) days.

Swrve has established an independent recourse mechanism under the Privacy Shield Framework, to investigate and mediate unresolved privacy complaints at no cost to individuals.  If you have contacted us with a privacy complaint related to our compliance with Privacy Shield and have not received a resolution within 45 days, you may file a claim with JAMS at www.jamsadr.com.

Last Updated: January 10, 2017