Privacy Policy

Swiftly Systems, Inc. (the “Company” or “Swiftly”) is committed to protecting and respecting your privacy and ensuring that your personal information is processed fairly and lawfully in line with all relevant privacy legislation. The purpose of this Privacy Policy is to set out the principles governing our use of personal information that we may obtain about you through the Swiftly Systems, Inc. website (“Website”) and if this Privacy Policy is referenced in any agreement, then through our relationship with you or your company for use of the Swiftly platform or services (“Services”) through Swiftly’s proprietary advertising/retailer application platform (the “Platform”) . By using the Website, you agree to our use of the personal information that we obtain about you.  

Please read this Privacy Policy carefully. The date the Privacy Policy was last revised is identified at the top of the page. We may change our Privacy Policy from time to time. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes. If a revision meaningfully reduces your rights, we will provide a prominent notice. BY USING THE WEBSITE, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT USE THE WEBSITE.

For your convenience, the Website may contain links to a number of other websites including Company’s retailer customers’ websites or applications. The privacy policies and procedures described here do not apply to those websites or applications; we suggest contacting those websites or applications owners directly for information on their data collection and distribution policies. Any reference to a linked website or application or any specific third-party product or service by name does not constitute or imply its endorsement by us, and you assume all risk with respect to its use.

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Your Data

We may collect, use, store and transfer the following information to provide, improve and protect our Website, the Platform or the Services.

The data we collect and process: You may give us personal information by visiting or interacting with the Website, filling in forms on the Website, or by corresponding with us by phone, e-mail, or otherwise. This personal information includes the following data which are referred to in this Privacy Policy as 'your data', 'your personal data' or 'your personal information':

• personal information you provide when you interact with the Website, Platform or Services. The personal information you give us may include your name, title, company, mailing address, email address, phone number, resume information, feedback, and any other information you choose to provide to us;
• technical data such as your internet protocol (IP) address, your login data, the web page you visited before visiting our Website, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and Website and other technology on the devices you use to access our Website;
• usage data which tells us how you use our Website, Platform or Services;
• marketing and communication data which tells us your preference in receiving marketing from us and our third parties and your communication preferences; and
• We do not collect sensitive personal information for purposes of using our Website.  However, if you supply such information in a fillable field or in an email communication to us then we may collect sensitive personal data.  Please note that we do not ask for any sensitive personal information and request that you omit any such information in any communications with us. If you send us sensitive personal information, we will delete it.

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Purposes for which we will use your data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request information or ask a question about our Services, we will use that personal information to respond to your inquiry.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• To fulfill any purpose for which you have provided or given us permissions to use the personal data.

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The ways we plan to use your personal data are as follows:

• Feedback. We collect feedback in order to improve our Website, Platform or Services.
• Usage. We also use your data, especially usage data and technical data, to evaluate and improve our Website.  Certain information about usage, type of browser or OS, date, time stamp and clickstream and data may be gathered and stored in log files. This information is anonymized, meaning that it cannot be tied to specific users.
• Cookies and other technologies. We use technologies like cookies to provide, improve, protect, and promote our Website. Cookies are data that are stored locally on the users’ devices. They are divided into Session ID cookies and Session Cookies, with the former being used to maintain users’ subscriptions and accounts. The data stored in cookies cannot identify individual users. Session cookies are used to improve your navigation on the Website itself, and expire once you close the Website. These data files are used in order to provide you with a comfortable experience when using our Website. Some browsers and/or mobile operating systems may have the possibility to remove or block cookies. Please note that some functionalities (For example, maintenance of your login due to Session ID cookies) may be limited. The Company currently does not respond to Do Not Track requests.  For additional general information about opting out of Cookies on your browser please visit: https://optout.networkadvertising.org/?c=1.

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Sharing your data

Others working for the Company. The Company uses trusted third parties (i.e. IT services, analytics services, etc.) to help us provide, improve, protect, and promote our Website, Platform and Services. These third parties will access your information only to perform tasks on our behalf in compliance with this Privacy Policy, and we’ll remain responsible for their handling of your information per our instructions.

Other applications and third-party links. The Website, Platform or Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our Website, we encourage you to read the privacy policies of every website you visit. Please remember that their use of your personal information will be governed by their privacy policies and terms.

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Protecting your data

We only process personal data where we have a legal basis for doing so. We review the personal data we hold on a regular basis to ensure it is being lawfully processed.

Before transferring personal data to any third party (e.g. suppliers, partners and back office support), we establish that there is a legal reason for making the transfer, which may include your consent.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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We have implemented measures and procedures that adequately protect the privacy of individuals and ensure that data protection is integral to all processing activities. This includes implementing measures which may include the following:

• Data minimization (e.g. not keeping data for longer than is necessary);
• Pseudonymization;
• Anonymization;
• Cyber security; and
• An Information Security policy.

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Your rights – individuals in the European Union (GDPR)

If you are an individual in the European Union, you have certain rights with respect to the access, correction, restriction, and erasure of your personal information stored on our Website, Platform or Services at any time if allowed by applicable law. You can exercise any of these rights at any time by contacting us at info@swiftlysystems.com. Your rights include the following:

• Accessing your data. Upon request, we shall provide any information relating to your data and our processing of your data in a concise, transparent, intelligible, and easily accessible form using clear and plain language. The information shall be provided in writing or by other means, including, where appropriate, by electronic means within 30 days of a written request.
• Correcting your data. You have the right to ask us to rectify any inaccurate or incomplete personal data on our Website. If we have given your personal data to any third parties, we will notify those third parties that the Company has received a request to rectify your personal data, unless doing so proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold - however, we are not in a position to audit those third parties to ensure that the rectification has occurred.
• Erasing your data. You can ask us to erase your personal data stored on our Website, Platform or Services if allowed by applicable law. If we receive a request to erase your data, we will ask you if you want your personal data to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot keep a record of individuals whose data we have erased so you may be contacted again by us, should we come into possession of your personal data at a later date.
  If we have given your personal data to any third parties, we will tell those third parties that the Company has received a request to erase your personal data, unless this proves impossible or involves a disproportionate effort. Those third parties should also rectify the personal data they hold - however, the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.
• Restricting the use of your data. We only process your personal data where we have the legal basis for doing so. You have the right to ask us to suspend or otherwise restrict the processing of your personal data where:
• You challenge the accuracy of the personal data;
• The processing is unlawful but you do not want us to erase it;
• We no longer need the personal data for the purposes of the processing, but you want us to hold it as you need it to establish, exercise, or defend legal claims; or
• You have objected to our use of your data, but we need to verify whether we have legitimate grounds to use it.

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If we have given the personal data to any third parties, we will tell those third parties that we have

received a request to restrict the use of your personal data, unless this proves impossible or involves a disproportionate effort. Those third parties should also rectify the personal data they hold - however, we will not be in a position to audit those third parties to ensure that the rectification has occurred.

Withdrawing your consent. Where we are relying on consent to process your personal data (for example consent to receive marketing) you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

Children under the Age of 13. The Children’s Online Privacy Protection Ace of 1998 and its rules (collectively, “COPPA”) require us to inform parents and legal guardians about our practices for collection, using and disclosing personal information from children under the age of 13. Our Website is not intended for children under 13 years of age. We do not knowingly collect any personal information from children under 13 years of age and we do not specifically market to children under the age of 13 years old. If you are under the age of 13, do not use or provide any information on our Website. If we learn we have collected or received personal information from a children under 13 we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@swiftlysystems.com.

California Online Privacy Protection Act. As required by the California Online Privacy Protection Act (“CalOPPA”) and the California Business and Professions Code, this Privacy Policy identifies the categories of personally identifiable information that we collect through our Website about individual consumers who use or visit our Website and the categories of third-party persons or entities with whom such personally identifiable information may be shared. Further, as required by CalOPPA this Privacy Policy includes specific disclosure in regards to Do-Not-Track signals and online behavioral tracking across third-party websites.

California Consumer Privacy Act of 2018 (CCPA). If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights under the CCPA, please see our Privacy Notice for California Residents [add hyperlink].

California Shine the Light Law (“Shine the Light”). California’s Shine the Light law permits user of our Website, Platform or Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email us at info@swiftlysystems.com.

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Where we store and transfer data

The Website is controlled by the Company from its offices in the United States. The Company may store and use information in the United States and other jurisdictions; any personal data provided to the Company will be transmitted to or within those jurisdictions. The Company also may transfer information and personal data to other jurisdictions to facilitate the Company’s third party processors’ access to and/or processing of information and/or personal data.

Individuals in the EU. Whenever we transfer your personal data outside the European Economic Area (“EEA”), we ensure a similar degree of protection is afforded to it as in the EEA by using specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe.

The Company makes no representation that materials on this Website are appropriate or available for use in other locations, and access to them from territories where their contents are illegal is prohibited. Those who choose to access this Website from other locations do so on their own initiative and are responsible for compliance with applicable local laws.

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Contact

Have questions or concerns about our Website or Privacy Policy? Contact us at info@swiftlysystems.com.