PRIVACY POLICY

SWURL, LLC. (“SWURL,” “We,” “Us,” “Site,” or “Our”) provides this Privacy Policy because we know that you care about how your information is collected, used, shared and retained. This Privacy Policy applies to information collected when you visit our website (www.getswurl.com) (our “Website”), access or use services that we make available from time to time through our platform, Website (collectively our “Platform”), or visit an offline location that makes this Privacy Policy available to you (collectively, the “Services”).

By using our Services or interacting with us offline you agree to the terms of this Privacy Policy and the accompanying Terms of Use, and consent to the collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Services. Capitalized terms not defined in this Privacy Policy have the meaning ascribed to them in the Terms of Use.

Personal Information We Collect

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

• “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

• “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

• SWURL utilizes third party "Squarespace" for opt-in email communications and here are the terms conditions and privacy: https://www.squarespace.com/privacy

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers and any other forms of payment submitted by customer, email address, and phone number. We refer to this information as “Order Information”.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

Purpose of Collection and Use

We use the information that we collect from you under this Privacy Policy for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information, including in the last 12 months, includes to:

• Provide our Website, App, Platform and related support;

• Process and ship Product orders;

• Perform services requested by you, such as respond to general inquiries, comments, questions, requests, and provide customer service;

• Prevent and address fraud, breach of policies or terms, and threats or harm;

• Monitor and analyze trends, usage, and activities;

• Conduct research, including focus groups and surveys;

• Develop and provide you direct marketing and relevant content on our Website, App and Platform, including advertisements regarding products and services of ours or other entities, and communications about our and other entities’ products, offers, promotions, rewards, events, and services;

• Conduct promotions, including verifying your eligibility and delivering prizes in connection with your entries;

• Fulfill any other business or commercial purposes at your direction or with your notice and/or consent.

How do we use your personal information?

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

• Communicate with you;

• Screen our orders for potential risk or fraud; and

• When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

Sharing You Personal Information

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Squarespace to power our online store – you can read more about how Squarespace uses your Personal Information here: https://www.squarespace.com/privacy. We also use Square and Stripe to process payments – you can read more about how Square and Stripe use your Personal Information here:

https://squareup.com/help/us/en/article/3796-privacy-and-security

https://stripe.com/privacy

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Analytics & Advertising

We use one or more analytics services (such as Google Analytics) to evaluate your use of the Platform, compile reports on activity based on our partners’ collection of IP addresses, internet service provider, browser type, and other similar usage information. These partners use cookies to collect this usage information. By accessing and using the Platform, you consent to the processing of data about you by these other entities in the manner and for the purposes set forth in this Privacy Policy.

We share your usage and contact information with third parties for marketing or advertising purposes, such as technology services for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., behavioral, contextual, and retargeting), analyzing, managing, reporting, and optimizing of ads).

You may opt-out of the tailoring of advertising based on information we collect. We also use technology services (for example, Google Adwords) to advertise to users of our Platform on websites owned or operated by other entities. This means that we advertise to previous visitors to the Website who have not completed a task on the Website, such as leaving un-purchased items in your shopping cart. For Google Adwords, you can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

We also use audience matching services to reach people (or people similar to people) who have visited our Services or are identified in one or more of our databases (“Matched Ads”). For example, We do this by uploading a customer list to a technology service or incorporating a pixel from technology service into our own Service, and the technology service matching common factors between our data and their data These technology services may act as our service provider and in some cases may retain our list for their matching purposes.

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Do Not Track

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

Your Rights

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

Data Retention

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at hello@getswurl.com