The Swaybase website and service is owned and operated by FirmPlay, Inc. (“FirmPlay”, “We” or “Our”). FirmPlay respects your right to privacy. This Privacy Policy explains who we are, how we collect, share and use personal information about you and how you can exercise your privacy rights.
Our Privacy Policy applies to all users of FirmPlay websites and services, including but not limited to www.swaybase.com (depending on your use, the “Site” and/or the “Service”). If you do not agree with the data practices described in this Privacy Policy, you should not use the Site or the Service.
What does FirmPlay do?
FirmPlay is a US-headquartered provider of software for social media-related marketing. For more information about FirmPlay, please visit our Site at www.swaybase.com.
Information Collected Directly From You
We collect information about visitors to our Sites, employees of our customers, and users who interact with digital content shared by our customers and their employees.
The type of information that we collect directly from you varies based on your interaction with our Site and our Service. We collect information directly from you when you register an account with us, liaise with us on a customer service issue, complete an application or other forms on the Site and/or software, including, but not limited to, name, email, telephone, social media handle, and social media profile image.
Information Collected Automatically
When you visit our Site or use our Service, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), third party webpages accessed via the Service and other technical information. We may also collect information about how your device has interacted with our Site, including the pages accessed and links clicked, or Service, including content accessed.
Collecting this information enables us to better understand the visitors who come to our Site or use our Service, where they come from, and what content and functionality is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Site and/or Service to our visitors and users.
Use of Personal Information
FirmPlay processes your personal information for the following purposes:
- Operate and improve the Site and Service;
- Provide users or customers with the Service and other products and services that a user or customer may request or that a user or customer has expressed interest in;
- Facilitate subscription processing, reviews and analysis;
- Evaluate user interest and needs in order to improve the Service and make available other offers, products or services;
- Evaluate the types of offers, products or services we make available to users or customers and potential users or customers;
- Monitor use of the Service;
- Provide customer support;
- Communicate and provide additional information that may be of interest to users through email or other means, such as special offers, announcements, and marketing materials;
- Conduct online research surveys regarding the Site and/or Service;
- Combine datasets to create aggregated data for internal evaluation and analysis;
- Share anonymized or personalized access tokens within the Service;
- Send you reminders, technical notices, updates, security alerts and support and administrative messages, service bulletins, or marketing;
- Provide advertisements to you through email messages; and
- Manage our everyday business needs such as Site and/or Service administration, fulfillment, analytics, fraud prevention, enforcement of our corporate reporting obligations, Terms of Use and any other contractual agreement relating to our Service or to comply with the law.
To Whom We May Disclose Your Information
We may disclose your information, including personal information, to the following categories of recipients:
- to our affiliates third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Site or Service), or who otherwise process personal information for purposes that are described in this Privacy Policy or notified to you when we collect your personal information.
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or court order or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy;
- to any other person with your consent to the disclosure.
We do not share personal information with third parties for their own marketing purposes.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Legal Basis for Processing Personal Information
If you are a visitor or user from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance of our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to Contact Us” heading below.
Cookies and Tracking Technologies – How to Opt Out
We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.
Cookies provide a convenience feature to save you time, or tell the Web server that you have returned to a specific page. For example, if you register for our Service, a cookie helps us to recall your specific information on subsequent visits. When you return to the Service, the information you previously provided can be retrieved, to make it easier for you to access and use the Service.
If you would prefer not to accept cookies or otherwise wish to disable our use of tracking technologies, most browsers and mobile devices allow you to change your settings so as to notify you when you receive cookies or other tracking technologies are being used, and to choose whether or not to accept/allow it. Most browsers also allow you to disable or delete existing cookies or to automatically reject future cookies. Disabling cookies may limit your ability to use the Services.
Certain tracking technologies we use are related to advertising networks, and through those technologies we may share certain information such as IP addresses. No personally identifiable information is shared with these advertising networks, but please note that the information we share with those advertising networks might be combined with other information about you that those networks may have collected from other sources. To learn more about advertising networks and how to opt out of sharing information with them, please click
here and
here. If you’re in the EU, you can find additional information about your choices with respect to advertising networks and online behavioral advertising by clicking
here.
Certain tracking technologies we use involve the use of session replay scripts or other scripts that run directly from your browser. If you wish to disable these tracking technologies, you can install a third-party browser analytics blocker plug-in such as
Ghostery.
If you have any questions about how we or our third-party service providers use cookies or other tracking technologies that aren’t answered in this Privacy Policy, please contact us at hello@swaybase.com.
Do-Not-Track
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this Privacy Policy (e.g., by disabling cookies, or using ‘private’ browsing modes).
Your Data Protection Rights
You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to Contact Us” heading below. Note that if you submit a request to delete your personal information, this may prohibit you using the Site and/or Service.
- In addition, if you are a resident of the European Union, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to Contact Us” heading below. Note that if you submit such a request, this may prohibit you using the Site and/or Service.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you.
- Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. Again, you can exercise this right by contacting us using the contact details provided under the “How to Contact Us” heading below. Note that if you submit such a request, this may prohibit you using the Site and/or Service.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Where we process your personal information solely on behalf of a customer, we may be legally required to forward your request directly to our customer and social media business partners for their review / handling.
Security & User ID/Password
Our Site and/or Service utilizes various appropriate technical and organizational security measures, which include, but are not limited to, network and host security controls (e.g., firewalls, intrusion detection systems, etc.), data encryption (both at rest and during transmission), and operating procedures that are designed to protect your personal information. You should protect your user ID and password and NOT share it with anyone. If you believe your user ID and password have been compromised or you have trouble changing your user ID/password on the Site or Service, please contact our technical support department at hello@swaybase.com.
Data Retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, in the limited circumstances where this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
CAN-SPAM Compliance Notice (U.S. and Canadian users only)
We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the unsubscribe or opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Service you have requested or received from us.
International Transfers (including outside of EU / EEA)
Your personal data may be stored and processed in any country where we have facilities or in which we engage third party service providers. By using the Site and/or Service, you consent to the transfer of information to countries outside your country of residence, including the United States, which may have different data protection rules than in your country. While such information is outside of the EU/EEA, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. Our practices regarding your personal data will at all times continue to be governed by this Privacy Policy and we will comply with GDPR requirements providing adequate protection for the transfer of personal data from the EU/EEA to a third country.
Children
The Site and Service are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at hello@swaybase.com, so that we may delete the information.
Updates to this Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. While we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically.You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.
How to Contact Us
If you have any questions about this Privacy Policy, to make an access or correction request, to exercise any applicable rights, or to make a complaint, please write to us by email at hello@swaybase.com or by mail to FirmPlay, Inc., 345 Pleasant St #9, Watertown, MA 02472 USA, Attn: Privacy.
