Privacy Policy

Effective Date: Mar 8th, 2019
GDPR

Swomi Group International, Ltd ("Swomi," we," us") is an "experience” based content driven marketing technology with monetization features where Users can connect links, channels, pipelines, syndication, streams, networks, communications, and other digital media and data to dynamically track, increase and optimize metrics for ideas, brands, passions, products and services.

Collectively, we describe our products and services including our websites, applications, network, mobile apps, platform, content, and hardware—as our "Services." This Privacy Policy explains how we treat information from or about our users, including how we collect, use, and share information in connection with our Services.

We collect Personal Data through websites such as swomi.com, swomibuzz.com, and swomichat.com (“Site”), as well as all related websites and subdomains, applications, browser extensions, and other Services provided by us (collectively, together with the Site, our “Service”), and in connection with our customer, vendor, and partner relationships.

Personal Data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

The Terms of Use, Privacy, Copyright Policies and Agreements including schedules and addendums of Swomi and Site are Collectively are referred to as the “Policies”.

We obtain Personal Data relating to you from various sources described and as outlined in the Policies. This policy also tells you about your rights and choices with respect to your Personal Data, and how you can reach us to update or modify the state of your information or get answers to questions you may have about our privacy practices.

User Content is content created by the User or from use of and within the Swomi platform as further defined in this Privacy Policy and Policies. Swomi Content means all of our Content and it is distinct from User Content. User Content is a subset of Content of that User. It means the User Content that you post, share of use.

Technical data is recorded when you visit our Sites such as domain name, IP address and region or geographical area, browser version, operating system, the website you passed through to reach our Site, and usage information such as the number and frequency of visitors to each Site and its various web pages or content through Social Sites, Cookies, Web Beacons, Pixel Tags, Behavioral Data and others, each of which is defined below.

Registration with us or use of and access to the Service is subject to the Policies located at https://swomi.com. All terms not defined in this Privacy Policy will have the meanings set forth in Swomi Terms of Use (“TOU”) and related Policies.

We adopted the principles of the GDPR on User rights with variation to take into account the differing conditions in the US and on Aggregation through non-identifiable methods as outlined in this document for functions of the Services. To review the EU policies click on the following links GDPR e-Privacy Directive and GDPR Documents.

We are always changing and improving our Services. We may add or remove functionalities or features, and we may suspend or stop a Service altogether. You can stop using our Services at any time, although we’ll be sorry to see you go. Your continued use of this Site after such notices constitutes your agreement to all such terms, conditions, notices and Policies. If you do not agree with any of these conditions, please do not use the site.

This Privacy Policy and related Policies include the ATP or Advertising & GDPR Technology Platforms addendum.


1. Collection of Personal Data from Users.
Users may be subject to different protection standards and broader standards may therefore apply to some. In particular the ContentSignals platform may collect personally identifiable data in order to apply monetization and payment for Users.

Generally speaking, you provide us with Personal Data by logging into or creating an account, providing feedback to us, posting a review or making other comments on any public forums, entering a contest or sweepstakes, filling out a survey, submitting other user-generated or submitted content which may be used for the ContentSignals monetization platform.

We may use non-personal data in the generic form to build quality, beneficial, online Services. We perform statistical analysis of the overall characteristics and behavior patterns of our customers. We may also provide non-Personal Data in aggregate form to third parties who provide a portion of the Services and technology that make up Swomi.com service so they can optimize, maintain, support and improve the service.

We may also share de-identified or aggregated information with third parties and advertisers so they can measure the effectiveness of any content or advertisements viewed in connection with our Sites and understand audiences. For example this information may provide the number of users who clicked on or viewed specific content or advertisements, and viewer’s preferences for those types of Content. We might also use such aggregated information to modify our Services for better performance or other reasons. Aggregated Data is also used in the ContentSignals algorithm for automated decision making and profiling.

Swomi and Data Controller
Swomi Group Internatinoal, Inc.
701 5th Avenue, Suite 4200
Seattle, WA, 98104
Swomi contact email: privacy@Swomi.com


2. Processing and ContentSignals©
The Personal and related Data herein referred to as “Data” concerning the User is collected to allow Swomi to provide its Services including identifying monetization opportunities. This involves many systems and processes including: remarketing and behavioral targeting, interaction with external social networks and platforms, tag management, traffic optimization and distribution, as well commercial affiliation.

Access to third-party accounts, user database management, analytics, social features, registration and authentication, managing contacts and sending messages, hosting and backend infrastructure, handling payments and contacting the User are all part of the processing and infrastructure of the ContentSignals and Swomi platform.

If you desire to have access to certain restricted sections of the Site or request to receive marketing materials, you may be required to become a registered user, and to submit the following types of Personal Data to Swomi: your name, email address, phone number, full user name, password, city, and time zone.

Users can find further detailed information about the specific Personal Data used for each purpose in this document, Policies and Swomi.com website.


3. Types of Data Collected
Among the types of Data that Swomi collects, by itself or through third parties, there are: Cookies, Usage Data, email address, username, picture, first name, last name, various types of Data, gender, date of birth, phone number, address, country, profession, company name and website.

Details on types of Data collected are provided in the Policies and as provided by the User in the case of usage data collected automatically when using Swomi.

Unless specified otherwise data requested by Swomi is required to provide Service and without this data may make it impossible for Swomi to provide its services. In cases where Swomi specifically states data is not mandatory Users are free not to communicate this data without compromising functions of the ContentSignals and Swomi.com platform and service.

Any use of Cookies or tracking tools by Swomi or third-party services used by Swomi is for the purpose of providing the Service required by the User in addition to other purposes described in the Policies.

Users are responsible for any third-party personal data shared, obtained, or published through Swomi and confirm they have third party's consent to provide that data to Swomi.


4. Processing of Data
Swomi takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data.

Data processing is carried out using computers and/or IT enabled tools following procedures and modes related to the purposes indicated. Company operations in some cases means the data may be accessible to certain types of persons in charge, involved with the operation of Swomi (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies).


5. Sharing of Account Data

The main sharing of your Personal Data comes when you want to establish an account, so we have to transmit your Personal Data to a third party that manages those accounts, which is currently Stripe. You are redirected to Stripe, where you establish your account, which is called the “Stripe Connect” service that generates the Stripe Access Token, Refresh Token, Publishable token, Account Type and user ID.

We may also share information with affiliates and business partners to whom it is reasonably necessary or desirable for us to disclose data for the purposes described in this Privacy Policy.


6. Basis for Processing
Swomi may process personal data if one of the following applies:

Users have given their consent for one or more purposes;
data is necessary for the provision and performance of an agreement with the User and/or for any pre-contractual obligation thereof;
a legitimate interest such as a legitimate interest to ensure and improve the safety, security, and performance of our platform and to anonymize and carry out data analyses;
provide you with Services and products requested by you to respond to your inquiries, we have a legal obligation;
ensure security
compliance with a legal obligation to which Swomi is subject;
in the public interest or in the exercise of official authority vested in Swomi;
necessary for the purposes of the legitimate interests pursued by Swomi or a third party.

Under some legislation Swomi may be allowed to process personal data until the User objects to such processing (“opt-out”), without having to rely on consent or any other legal bases. This however may not apply whenever the processing of data is subject to GDPR European data protection law.


7. Location of Data
The Data is processed at Swomi's operating offices and authorized devices, in any other places where the parties systems and infrastructure involved in the processing are located.

Depending on the User's location data transfers may involve transferring the User's data to a country other than their own such as Swomi’s network, hubs, processing and data centers.

Data transfers outside the European Union or to international organization are governed by public international law or as set by two or more countries, such as in the UN, regarding security measures taken by Swomi to safeguard data. If any such transfer takes place Users can find out more by checking the relevant sections and sources of information in this document or as provided in the Policies.


8. Data Retention
Personal and system data shall be processed and stored for as long as required for the purpose they have been collected for.

Personal and system data collected for purposes related to the performance of a contract or agreement between Swomi and the User shall be retained until such contract or agreement has been fully performed or terminated by the Courts or per policies outlined herein;
Personal and system data collected for the purposes of Swomi’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific types and use of such information within the relevant sections of this document or the relevant Policies.

We will keep your account information for as long as your account remains open and then after that for as long as necessary to fulfill obligations and receive the benefits of any agreement we have with you in the Policies.

When determining retention period for data we may take into account various criteria, such as the nature and length of our relationship with you, possible re-enrollment with our products or Services, the impact on the Services we provide to you if we delete some information from or about you, mandatory retention periods provided in the Policies, or by law and the statute of limitations.

Swomi may be required and allowed to retain personal data for a longer period whenever the User has given consent to such processing as long as such consent is not withdrawn or performance of a legal obligation or upon order of an authority.

Once the retention period expires personal data shall be deleted. The right to access the right to erasure and/or the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document, Policies and Swomi.com website.


9. Social Media and Data Access
When you log-in to a Site through social media platform Personal Data can be exchanged based on the Sites you visit or other Services you use. This data includes username, account ids, social username, time zones, and email address. We may also collect your contact details when you provide them in the context of our customer, vendor, and partner relationships. If you connect your third party account to a Swomi account, we may collect certain information stored in your account such as profile image, display name, username / page ID or profile ID, access tokens, sent posts. This includes the content of your post and engagement data (such as click rates, likes, re-shares, impressions, as well as general engagement counts), to the extent permitted by applicable law.

This data will only be used by Swomi to provide you with the Service you expect and will not be shared with any third parties. Additionally, if you connect to social platforms when utilizing Swomi we may collect social accounts insights data and social accounts demographic data, sent tweets, social account’s followers count, social account’s insights data and social account’s audience data. When you use our Service, our servers automatically record information that your browser sends whenever you visit a website. This Data may include information such as your IP address, browser type or the domain from which you are visiting, the web-pages you visit, the search terms you use, and any advertisements on which you click.


10. Cookies
We use our own Cookies and information from third party Cookies. Third party Cookies are typically inserted into your computer when you visit websites of third parties (i.e., not one of our Sites) long before you visit one of our sites. We do not control when or how third parties place Cookies on your computer.

Like many websites, we use “cookie” technology to collect additional website usage data and to improve the Site and our Service. Cookies collect and record information such as your domain name, IP address. A session cookie which enables certain features of the Site and our service and is deleted once you disconnect from or leave the Site. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. Persistent cookies can be removed by following your web browser help file directions. Most Internet browsers automatically accept cookies to monitor aggregate usage by our users and web traffic routing on the Site, and to improve the Site and our Service.

Cookies are also used to enable your use of the Services such as storing your login information to accelerate that process or to respond to your preferences. We also use Technical Information to customize our infrequent newsletters, as well as advertising and Site content based on browser type and user profile information. The Technical Information may also provide measurements of overall and specific activity on our Sites in the use of other Services, allowing us to modify the look-and-feel, content and performance of our Services.


11. Web Beacons and Pixel Tags
Web beacons, also known as “one-pixel gifs”, “clear gifs”, “web bugs”, “Internet tags” or “pixel tags”, and other small graphic images (usually invisible) that can be embedded in content and advertising on a website or in an email. These may be embedded on Sites and advertisements there or on third party sites you visit from our platform. Web beacons can recognize certain types of information on your browser, check whether you have viewed a web page or email message and record data such as time and date that you viewed the web beacon, the IP address of your computer, and the URL of the web page from which the web beacon was viewed. Web beacons are used in this function to improve your experience, including to provide you with content customized to your interests, related services, features, content, applications and functionality.


12. Behavioral Data, Webhooks & Tags
We may also automatically record certain behavioral information from your device by using various types of technology, including web beacons, webhooks and tags including geotagging for location. This collected information may include your IP address or other device information, web browser, device type, web pages, sites that you visited, and the dates and times that you visited. We also use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message, to the extent permitted under applicable law. This information is used to provide Service such as automation and ContentSignals implementation.


13. How We Use Personal Data for Users<
We primarily use the Personal Data we receive to provide our Services. We also use the Data to properly maintain our Site and our services and to make improvements or upgrades and send newsletters about topics that we believe are of interest to you as well as throughout the ContentSignals network. We may also use the Data to inform you of products or services from us or others that may be of interest to you and to respond to your inquiries or to enable selected third parties to perform certain services such as maintain our databases or provide us with emailing capabilities when we send our occasional newsletter or for you to establish an account for us to pay.

We also use Data to prevent fraud, including the unauthorized use of this Site or our services or violations of applicable policies and the Terms of Service and to ensure compliance with the law. We may also use Data to resolve disputes, troubleshoot problems, and enforce our agreements with you, including the Terms of Service or this Privacy Policy.


14. Content Data and Re-Publication
Requests from other media companies to license some User Content on our Sites will not be provided without first obtaining the express consent of the user that created that User Content. If that user does not consent we do not share the relevant Personal Data with that media company.


15. Ad Networks and Data
Some advertising is delivered by third-party Internet advertising companies (also called “ad networks” or “network advertisers”). The rest of the ads are our own. Ad networks may use Cookies, web beacons and other technologies to collect information about your use of the Site or third-party websites to deliver advertisements, measure effectiveness and personalize advertising content. The information practices of these advertising companies are governed by their own privacy policies and are not covered by this Privacy Policy.

Some of these advertising companies may be members of the Network Advertising Initiative (“NAI”) https://http://www.networkadvertising.org/, a cooperative of online marketing companies that offers a centralized tool for opting out of behavioral advertising delivered by each of its member companies.

The Digital Advertising Alliance (“DAA”) http://www.networkadvertising.org/choices a group of media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different websites. To make choices about interest-based ads from participating third parties, please visit the DAA consumer opt out page.


16. Third Party Sharing Personal Data
We may use third parties vendors to provide the Services and technology such as Instagram API, Facebook Open Graph, Twitter API, Google Analytics and personalized ads from using Ad Technology Providers or ATP as in the ATP Addendum. Swomi.com may provide these third parties with access to Personal Data specifically for use in connection with providing such Services and techniques. We may at times, use third parties to act on our behalf for projects such as market-research surveys or will contract with third parties to provide co-branded products. We may disclose Personal Data about you as described in the Policies or otherwise disclosed at the time the data is collected, including with social media platforms, service providers such as for hosting and maintenance, error monitoring, debugging, performance monitoring, billing, customer relationship, database storage and management, and direct marketing campaigns but only to the extent necessary to perform these functions and provide such Services.

We may use non-personal data in the generic form to build quality, beneficial, online Services. We perform statistical analysis of the overall characteristics and behavior patterns of our customers. We may also provide non-Personal Data in aggregate form to third parties who provide a portion of the Services and technology that make up Swomi.com service so they can optimize, maintain, support and improve the service.

We may share or disclose your personal data is: required to do so by law, court order, as requested by other government or law enforcement authority; in the good faith belief that disclosure is necessary or advisable including, without limitation, to protect the rights or properties of Swomi.com; we have reason to believe that disclosing the information is necessary to stop someone who may be meddling with our rights or properties, whether it has intent or otherwise; or other people could be injured by such activities.


17. User Request or Changes In Data Settings
Requests for changes in data settings may not be possible or above all will have certain consequences that might be negative to you or the platform. If you request to have specific Personal Data erased, then you may not be able to use your account and other Services that rely on access to this Data.

We will verify you are who you are making requests to data settings. We might not comply with your requests if we believe that the changes you wish to make are fraudulent or not truthful or accurate. In addition, we will not remove Personal Data that is archived for legal purposes, such as responding to government requests.


18. Changing Your Browser Settings:
You can instruct your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you delete, or choose not to accept, cookies you may not be able to utilize all the features to their fullest potential. Swomi does not process or respond to web browsers that have “do not track” or other settings for transmissions that indicates a request to disable online tracking of users.


19. Submitted Content
You can engage with and contribute with Swomi.com and your Services by providing recommendations, reviews, or opinions for public display on Swomi.com ("Submitted Content"). Do not post personally identifiable information if you wish to remain private in your Submitted Content it can be used and viewed by others. We are not liable for the information you choose to include in your Submitted Content.


20. Protecting Your Information
Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and Personal Data by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account.


21. Third Party Plugins
Our website uses plugins such as for social media which may be used by the social network facebook.com and other social site plugins which are operated by social media entities. All the cookies, images, videos, statistics and other components of these Social plugins are in order of their terms or use. See the Privacy Statement and Privacy Policy of each social providers.


22. Third Party Links
A link to our website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. Other websites may place their own cookies or other files on your computer, collect data or solicit Personal Data from you. We assume no responsibility for the privacy practices of such Third Party Services. We encourage you to review the privacy policies posted on those, and all, Third Party Services.


23. How We Protect Your Data
Swomi is very concerned about safeguarding the confidentiality of your Personal Data. We employ electronic measures designed to protect your Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. There are no perfect security measures or impenetrable technologies therefore cannot guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our administrative, physical, and electronic safeguards, subject to requirements under applicable law to ensure or warrant information security.

We cannot guarantee the security of our database or our Sites or other Services, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet. We are not responsible for the actions of third parties.


24. Deactivating Your Account:
You can deactivate your account. Please note that we will need to verify that you have the authority to deactivate the account. Activity generated prior to deactivation will remain stored by us and some of it may be publicly accessible as set out in this Privacy Policy and Policies. Should you ever decide to deactivate your account, you may do so by emailing support@swomi.com.

When posting User Content under these Policies we might continue to post it after your account is deactivated. Any association between your account and information we store will no longer be accessible through your account. However, any public activity on your account prior to deletion will remain stored on our servers and might remain accessible to the public. In addition, we will keep archived copies of your Personal Data for the legal purposes such as legal or government requests.


25. Data Transfers Outside US
Swomi is based in the United States and Personal Data we collect may be transferred to, and stored at, affiliates, partners or service providers inside the European Economic Area (“EEA”) and Switzerland, including the United States and may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information.


26. Guardian Children’s Policy
The Site is not directed to persons under 16 years of age. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, he or she should contact us at support@swomi.com. We do not knowingly collect Personal Data from children under 16 years of age. If we become aware that a child under 16 years of age has provided us with Personal Data, we will delete such information from our files and as outlined in this Privacy Policy.


27. Administrative Messages
Please be aware that, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the service. In certain jurisdictions you have the right to request access and receive information about the Personal Data we maintain about you, to update and correct inaccuracies in your Personal Data, to restrict or object to the processing of your Personal Data, to have the information blocked, anonymized or deleted, as appropriate, or to exercise your right to data portability to transfer your Personal Data to another company. Those rights may be limited in some circumstances by local law requirements. In addition to the above-mentioned rights, you also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.

Where required by law, we obtain your consent for the processing of certain Personal Data collected by cookies or similar technologies, or used to send you direct marketing communications, or when we carry out other processing activities for which consent may be required. If we rely on consent for the processing of your Personal Data, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.


28. Updating or Correcting Data
Your personal profile, which includes member registration and policy information, can be updated through your account on Swomi.com. Because of the way we store information, after you update your information or request that your account is deactivated for marketing purposes, residual copies of your information may remain in our active servers for a period and may remain in our backup systems. Some requests that we deem are unreasonably repetitive require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical may be rejected. Information may also be retained as required by law or for legitimate business purposes.


29. Safeguards in Place To Protect Data
While no website can promise complete security, we have incorporated the latest technical and physical security procedures designed to protect your personal data. Only authorized personnel are permitted to access personal data, and they may only do so for permitted business functions. Also, we use encryption when transmitting your private data between systems. We employ firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to your information.


30. International Users
Swomi.com is based in the United States, and, regardless of where you use our Services or otherwise provide information to us; the information may be transferred to and maintained on servers located in the U.S. or other countries. Note that the laws, regulations and standards of the country in which this information is stored may be different from your country. By using our Services, you consent to this collection, transfer, storage, and processing of information to and in the U.S. and other countries.

The EEA or European Economic Area includes the members states of the European Union and Iceland, Lichtenstein and Norway. Users in or from those countries have rights under the regulation for that region, the General Data Protection Regulation (known as the “GDPR”) including, for example, having us change or remove all or part of the Personal Data we hold.

For those users, this Privacy Policy applies and incorporates into it the GDPR privacy provisions. If you are such a user then consent to those terms. For EEA users, if there are any conflicts between the provisions at that link and the provisions of this Privacy Policy, then those provisions will prevail.


31. Privacy Protection for Children
Under Section 16 CFR Part 312 Children's Online Privacy Protection Act (COPPA) of 1998, 15 U.S.C. 6501–6505; mandates rules on operators of websites or online website's directed to children under 13 years of age, and on operators of other websites that have actual knowledge that they are collecting Personal Data online from a child under 13 years old. We do not knowingly collect any data from such children. If you are under the age of 13, do not submit any information to this Site. Any Information inadvertently collected from children under the age of 13 will be deleted as soon as possible.

Under California law, individuals under 18 who are users have rights of removal of Personal Data about them. If you are under 18 and there is an account in your name or the name of that child, then on request the Personal Data, and upon verification of identity, can be removed by emailing at the address in this Privacy Policy. To verify your identity and request we may need to contact you for further verification. Please also note that such removal might not be comprehensive because relevant User Content has been re-posted elsewhere or in archives, backups or maintained for purposes noted in the Policies.


32. California Privacy Rights
Residents of California have the right to request a disclosure describing what types of Personal Data we have shared with third parties for their direct marketing purposes, and with whom we have shared it, during the preceding year. You may request a copy of that disclosure by contacting us at support@swomi.com.

California has a privacy law known as the “Shine the Light” law. That law applies to our Sites because they are accessible in California. The law (at Civil Code Section 1798.83) gives California users the right to prevent us from disclosing their Personal Data to third parties that use such information for their direct marketing purposes. The law also requires certain companies to respond to California users requests to disclose business’ practices related to disclosing Personal Data to third parties for those direct marketing purposes.

We strive to de-identify data and add “Online Erasure” functions as under Business and Professions Code Sections 22580-22582 to allow registered users who are under the age of 18 and residents of California to request removal of User Content they post which may be invisible to others.

Please understand that someone might have copied User Content you have already posted and we will not be able to remove such copies. We might also choose simply to render that User Content invisible to other users and the public (rather than deleting it). We might also have to archive it for legal purposes as we explain in this Privacy Policy below.


33. Exclusions
This Privacy Policy shall not apply to any unsolicited information you provide to us. This includes, but is not limited to, information posted to any public areas of our web site, such as bulletin boards (collectively, "Public Areas"), any ideas for new products or modifications to existing Services, and other unsolicited submissions (collectively, "Unsolicited Information"), including all User Content, as that term is defined in our Terms of Use, that by its nature is accessible or intended to be accessible to other users of the Services. All such Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution. Please also note that any Personal Data or other information you provide to be displayed in your publicly available online profile will be displayed for others to see and thus will not be subject to the terms of this Privacy Policy. We cannot and will not be responsible for what third parties do with any Personal Data or other information that you choose to make publicly available. As such, we advise that you exercise great care in determining what information you choose to make publicly available through the Services.


34. Future Business Structure
We may, in the future, decide to sell, merge, or otherwise reorganize our business or assets. We reserve the right to transfer and disclose Data in these circumstances to an entity acquiring the company or relevant assets. You acknowledge that such transfers may occur and that any acquirer of us or our assets may continue to use your Data as set forth in this Privacy Policy or in a different policy that they elect to adopt.


35. Change What You Receive from Us
If at any time you wish to stop receiving marketing communications from us usually it can be done with an unsubscribe button or link. You may request to change the respective settings in your data or profile settings on the Site as available or contact us at privacy@swomi.com to make this request.


36. Updates To This Policy
This Privacy Policy may be updated from time to time for any reason; each version will apply to information collected while it was in place.

In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address or generate a click link, pop-up or similar notification when you access the Service for the first time after such material changes are made. Your continued use of the Service after the revised Privacy Policy has become effective indicates that you have read, understood and agreed to the current version of this Privacy Policy.

Your use after you have seen the notice will be consent of the changes, unless you are a user in the EEA, in which case you will click on the link, pop-up or similar notification to consent.


37. How To Contact Us
Swomi is the entity responsible for the processing of your Personal Data. If you have any questions or comments regarding this Privacy Policy, or if you would like to exercise your rights to your Personal Data, you may contact us by emailing us at support@swomi.com or by writing to us at:

Swomi Group International, Ltd
701 5th Avenue, Suite 4200
Seattle, WA
USA, 98104


ATP ADDENDUM - Ad & GDPR Technology Providers List


Google
https://www.google.com/policies/technologies/partner-sites/
Aarki
http://corp.aarki.com/privacy
Adacado
https://www.adacado.com/privacy-policy-april-25-2018/
Adara Media
https://adara.com/2018/04/10/adara-gdpr-faq/
AdClear
https://www.adclear.de/datenschutzerklaerung/
ADEX
http://theadex.com
Adform
https://site.adform.com/uncategorized/product-and-services-privacy-policy/
Adikteev
https://www.adikteev.com/eu/privacy/
AdLedge
https://adledge.com/data-privacy/
Adloox
http://adloox.com/disclaimer
Adludio
https://adludio.com/termsandconditions
AdMaxim
http://www.admaxim.com/admaxim-privacy-policy/
Admedo
https://www.admedo.com/privacy-policy
Admetrics
https://admetrics.io/en/privacy_policy/
Adobe Advertising Cloud
https://www.adobe.com/privacy/general-data-protection-regulation.html
AdRoll, Inc.
https://www.adroll.com/gdpr
AdTriba
https://privacy.adtriba.com/
advanced STORE GmbH
https://www.ad4mat.com/en/privacy/
Adventori
https://www.adventori.com/fr/avec-nous/mentions-legales/
advolution.control
http://advolution.de/privacy.php
affilinet
https://www.affili.net/uk/footeritem/privacy-policy
Akamai
http://www.akamai.com/compliance/privacy
Amazon
https://www.amazon.co.uk/gp/help/customer/display.html?nodeId=201909010
Amobee
https://www.amobee.com/trust/privacy-guidelines
Analights
https://analights.com/docs/analights-consent-to-the-processing-of-personal-data-en.pdf
AppLovin Corp.
https://www.applovin.com/privacy
AppNexus
https://www.appnexus.com/en/company/platform-privacy-policy
Arrivalist
https://www.arrivalist.com/privacy#gdpr
AudienceProject
http://privacy.audienceproject.com/for-users/
Aunica
https://www.aunica.com.br/privacy/privacy.html
Avocet
http://avocet.io/privacy-portal
Batch Media
http://batch.ba/datenschutzerklarung/
BDSK Handels GmbH & Co. KG
https://www.xxxlutz.de/ocms/privacy
Beeswax
https://www.beeswax.com/privacy.html
Betgenius
http://betting.geniussports.com/connextra-service-terms-conditions/
Blismedia
http://www.blis.com/privacy/
Bombora
http://bombora.com/privacy
Booking.com
https://www.booking.com/content/privacy.en-gb.html
C3 Metrics
https://c3metrics.com/privacy
Cablato
http://cablato.com/privacy
Celtra
https://www.celtra.com/privacy-policy/
Centro
https://www.centro.net/privacy-policy/
Cint
https://www.cint.com/participant-privacy-notice/
Clinch
https://clinch.co/pages/privacy.html
Cloud Technologies
http://green.erne.co/assets/PolicyCT.pdf
Cloudflare
https://www.cloudflare.com/security-policy/
Commanders Act
https://www.commandersact.com/en/privacy/
comScore
https://www.comscore.com/About-comScore/Privacy-Policy
Conversant/CJ Affiliate
https://www.conversantmedia.eu/legal/privacy-policy
Crimtan
https://crimtan.com/privacy-ctl/
Criteo
https://www.criteo.com/privacy/
CUBED
http://cubed.ai/privacy-policy/gdpr/
DataXu
https://www.dataxu.com/gdpr/
Delta Projects
http://www.deltaprojects.com/data-collection-policy/
Demandbase
https://www.demandbase.com/privacy-policy/
DENTSU
http://www.dentsu.co.jp/terms/data_policy.html
Dentsu Aegis Network
http://www.dentsu.com/termsofuse/data_policy.html
Digiseg
http://www.digiseg.io/GDPR/
DMA Institute
https://www.dma-institute.com/privacy-compliancy/
DoubleVerify
https://www.doubleverify.com/privacy/
Dstillery
https://dstillery.com/privacy-policy/
DTS
https://client.adhslx.com/privacy.html
EASYmedia
https://www.rvty.net/gdpr
eBay
https://www.ebay.com/help/policies/member-behaviour-policies/user-privacy-notice-privacy-policy?id=4260#section12
ebuilders
http://ebuilders.nl/privacy
Effinity
https://www.effiliation.com/politique-confidentialite.html
emetriq
https://www.emetriq.com/datenschutz/
Ensighten
https://www.ensighten.com/privacy-policy/
Essens
https://essens.no/privacy-policy/
ESV
https://www.wizaly.com/terms-of-use#privacy-policy
Evidon
https://www.evidon.com/resources/privacy-statement/
Exactag
https://www.exactag.com/en/data-privacy/
Exponential
http://exponential.com/privacy/
Facebook
https://www.facebook.com/about/privacy/update
Flashtalking
http://www.flashtalking.com/first-party-ad-serving/
Fractional Media
https://www.fractionalmedia.com/privacy-policy
FUSIO BY S4M
http://www.s4m.io/privacy-policy/
Gemius
https://www.gemius.com/cookie-policy.html
GfK
https://sensic.net/
GP One
http://www.gsi-one.org/templates/gsi/en/files/privacy_policy.pdf
GroupM
https://www.groupm.com/privacy-policy
gskinner
https://createjs.com/legal/privacy.html
Haensel AMS
https://haensel-ams.com/data-privacy/
Havas Media France - DBi
http://www.centraltag.com/commercial/policy/index.action
hurra.com
http://www.hurra.com/impressum
IBM
https://www.ibm.com/customer-engagement/digital-marketing/gdpr
Ignition One
https://www.ignitionone.com/privacy-policy/gdpr-subject-access-requests/
Impact
https://impact.com/privacy-policy/
Index Exchange
http://www.indexexchange.com/privacy/
Infectious Media
https://impressiondesk.com/
Innovid
http://www.innovid.com/privacy-policy
Integral Ad Science
http://www.integralads.com/privacy-policy
intelliAd
https://www.intelliad.de/datenschutz
Interpublic Group
https://www.interpublic.com/privacy-notice
IPONWEB
http://www.bidswitch.com/privacy-policy/
Jivox
http://www.jivox.com/privacy/
Kantar
https://www.kantarmedia.com/global/privacy-statement
Kochava
https://www.kochava.com/support-privacy/
LifeStreet
http://www.lifestreet.com/privacy
Liftoff
https://liftoff.io/privacy-policy/
Criteo
https://www.criteo.com/privacy/
CUBED
http://cubed.ai/privacy-policy/gdpr/
DataXu
https://www.dataxu.com/gdpr/
Delta Projects
http://www.deltaprojects.com/data-collection-policy/
Demandbase
https://www.demandbase.com/privacy-policy/
DENTSU
http://www.dentsu.co.jp/terms/data_policy.html
Dentsu Aegis Network
http://www.dentsu.com/termsofuse/data_policy.html
Digiseg
http://www.digiseg.io/GDPR/
DMA Institute
https://www.dma-institute.com/privacy-compliancy/
DoubleVerify
https://www.doubleverify.com/privacy/
Dstillery
https://dstillery.com/privacy-policy/
DTS
https://client.adhslx.com/privacy.html
EASYmedia
https://www.rvty.net/gdpr
eBay
https://www.ebay.com/help/policies/member-behaviour-policies/user-privacy-notice-privacy-policy?id=4260#section12
ebuilders
http://ebuilders.nl/privacy
Effinity
https://www.effiliation.com/politique-confidentialite.html
emetriq
https://www.emetriq.com/datenschutz/
Ensighten
https://www.ensighten.com/privacy-policy/
Essens
https://essens.no/privacy-policy/
ESV
https://www.wizaly.com/terms-of-use#privacy-policy
Evidon
https://www.evidon.com/resources/privacy-statement/
Exactag
https://www.exactag.com/en/data-privacy/
Exponential
http://exponential.com/privacy/
Facebook
https://www.facebook.com/about/privacy/update
Flashtalking
http://www.flashtalking.com/first-party-ad-serving/
Fractional Media
https://www.fractionalmedia.com/privacy-policy
FUSIO BY S4M
http://www.s4m.io/privacy-policy/
Gemius
https://www.gemius.com/cookie-policy.html
GfK
https://sensic.net/
GP One
http://www.gsi-one.org/templates/gsi/en/files/privacy_policy.pdf
GroupM
https://www.groupm.com/privacy-policy
gskinner
https://createjs.com/legal/privacy.html
Haensel AMS
https://haensel-ams.com/data-privacy/
Havas Media France - DBi
http://www.centraltag.com/commercial/policy/index.action
hurra.com
http://www.hurra.com/impressum
IBM
https://www.ibm.com/customer-engagement/digital-marketing/gdpr
Ignition One
https://www.ignitionone.com/privacy-policy/gdpr-subject-access-requests/
Impact
https://impact.com/privacy-policy/
Index Exchange
http://www.indexexchange.com/privacy/
Infectious Media
https://impressiondesk.com/
Innovid
http://www.innovid.com/privacy-policy
Integral Ad Science
http://www.integralads.com/privacy-policy
intelliAd
https://www.intelliad.de/datenschutz
Interpublic Group
https://www.interpublic.com/privacy-notice
IPONWEB
http://www.bidswitch.com/privacy-policy/
Jivox
http://www.jivox.com/privacy/
Kantar
https://www.kantarmedia.com/global/privacy-statement
Kochava
https://www.kochava.com/support-privacy/
LifeStreet
http://www.lifestreet.com/privacy
Liftoff
https://liftoff.io/privacy-policy/
Criteo
https://www.criteo.com/privacy/
CUBED
http://cubed.ai/privacy-policy/gdpr/
DataXu
https://www.dataxu.com/gdpr/
Delta Projects
http://www.deltaprojects.com/data-collection-policy/
Demandbase
https://www.demandbase.com/privacy-policy/
DENTSU
http://www.dentsu.co.jp/terms/data_policy.html
Dentsu Aegis Network
http://www.dentsu.com/termsofuse/data_policy.html
Digiseg
http://www.digiseg.io/GDPR/
DMA Institute
https://www.dma-institute.com/privacy-compliancy/
DoubleVerify
https://www.doubleverify.com/privacy/
Dstillery
https://dstillery.com/privacy-policy/
DTS
https://client.adhslx.com/privacy.html
EASYmedia
https://www.rvty.net/gdpr
eBay
https://www.ebay.com/help/policies/member-behaviour-policies/user-privacy-notice-privacy-policy?id=4260#section12
ebuilders
http://ebuilders.nl/privacy
Effinity
https://www.effiliation.com/politique-confidentialite.html
emetriq
https://www.emetriq.com/datenschutz/
Ensighten
https://www.ensighten.com/privacy-policy/
Essens
https://essens.no/privacy-policy/
ESV
https://www.wizaly.com/terms-of-use#privacy-policy
Evidon
https://www.evidon.com/resources/privacy-statement/
Exactag
https://www.exactag.com/en/data-privacy/
Exponential
http://exponential.com/privacy/
Facebook
https://www.facebook.com/about/privacy/update
Flashtalking
http://www.flashtalking.com/first-party-ad-serving/
Fractional Media
https://www.fractionalmedia.com/privacy-policy
FUSIO BY S4M
http://www.s4m.io/privacy-policy/
Gemius
https://www.gemius.com/cookie-policy.html
GfK
https://sensic.net/
GP One
http://www.gsi-one.org/templates/gsi/en/files/privacy_policy.pdf
GroupM
https://www.groupm.com/privacy-policy
gskinner
https://createjs.com/legal/privacy.html
Haensel AMS
https://haensel-ams.com/data-privacy/
Havas Media France - DBi
http://www.centraltag.com/commercial/policy/index.action
hurra.com
http://www.hurra.com/impressum
IBM
https://www.ibm.com/customer-engagement/digital-marketing/gdpr
Ignition One
https://www.ignitionone.com/privacy-policy/gdpr-subject-access-requests/
Impact
https://impact.com/privacy-policy/
Index Exchange
http://www.indexexchange.com/privacy/
Infectious Media
https://impressiondesk.com/
Innovid
http://www.innovid.com/privacy-policy
Integral Ad Science
http://www.integralads.com/privacy-policy
intelliAd
https://www.intelliad.de/datenschutz
Interpublic Group
https://www.interpublic.com/privacy-notice
IPONWEB
http://www.bidswitch.com/privacy-policy/
Jivox
http://www.jivox.com/privacy/
Kantar
https://www.kantarmedia.com/global/privacy-statement
Kochava
https://www.kochava.com/support-privacy/
LifeStreet
http://www.lifestreet.com/privacy
Liftoff
https://liftoff.io/privacy-policy/