Swoop Privacy Statement

Last Updated: 5 February 2024

• INTRODUCTION

  Swoop’s platform enables digital, health-related marketing to be done in the most privacy-enhancing and compliant way. We are committed to providing consumers, caregivers, and healthcare professionals (“HCPs”) with access to relevant and timely information, messaging, and knowledge to improve their healthcare journey.  Our products and services (the “Swoop Services”) enable healthcare and life sciences companies and brands to analyze the characteristics of content in order to optimize and enhance their marketing and analytics investments relating to advertising and outreach. Publishers and advertisers can use this contextual intelligence to develop and display content on the Internet in the right locations at the right time, without using traditional models that rely on tracking users’ internet activity to specifically target them. 
  
  We believe that health-related marketing and advertising should not involve a choice between responsible data and technology practices or effective marketing tools and strategies.  In fact, we aim to do both, and we have designed and built our offerings with that in mind.  Our privacy program is designed around trust, transparency, and respecting your rights in your personal information.  This Privacy Statement describes how we process personal information and other data relevant to Swoop Services, including information we collect, how we use it, how we may share it, and your rights with respect to your personal information.    
  
  If you are interested in learning more about your privacy rights and the choices available to you, see the “Your Privacy Rights and Choices” section below.

• SCOPE

  This Privacy Statement describes the personal information and other relevant data that we collect or process as part of:  

  • Our Website – our corporate website located at www.swoop.com.
  • Events and Marketing – our sponsored events and marketing activities
  • Business Contacts – personal information we may collect from representatives of our current and prospective customers and vendors (e.g., contact information, name, email, address, etc.), and
  • The Swoop Services – personal information licensed or obtained by Swoop, including from third parties, for use in the Swoop Products, such as demographic data and certain non-public personal information related to healthcare professionals (“HCPs”)

  
  This Privacy Statement does not apply to the following types of information:  

  • Information of Minors – We do not knowingly collect, sell or share personal information about persons under the age of 18. The Swoop Services, our website, and all of our Swoop-sponsored events, activities, marketing and outreach are intended for a business audience and not for any individual under 18 years of age.  
  • Employee or Job Applicant Data – personal information of or related to candidates for employment at Swoop, as well as past, present, and future Swoop workers, is not governed by this privacy policy; for more information, candidates and employees should reach out to Swoop human resources
  • Third Party Services – personal data that any third-party collects in connection with services not offered or controlled by Swoop (such as social media services)
  • Client or Third-Party Data – personal information (and any other data) that Swoop processes solely on behalf of, or that it receives from, its business customers in connection with providing the Swoop Services
  • De-Identified Data – any consumer or other data that has been “de-identified” and that may be processed as part of the products and services we offer to our business customers; in sum, we may use privacy-enhancing and technical protection measures like de-identification to prevent data from being reasonably associated with you. When we de-identify data, we take reasonable steps to help ensure that the de-identified data is not re-identified and require the same commitment from any third parties to which we disclose de-identified data. De-identified data is not personal information.

  
  Please click here to submit a request to exercise your privacy rights, including to opt-out of the sale or sharing of your personal information.  You may also choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). Where available, we will process the GPC signal as a request to opt out. 

• INFORMATION WE COLLECT (Notice at Collection of Personal Information)

  (A) Website

  When you visit our websites, we collect the following types of information.

  Category of Information	Description
  Device and Usage	This information may include, for example, the date and time of your visit, the pages you view immediately before and after you access our website, as well as how you engage with our business customer tools, and information related to how are products and services are performing
  Registration Information	When you respond to surveys, request information about the Swoop Services, register for events, subscribe to our publications, or engage in any similar activities through our website, we collect information that you provide through that process, such as your name, email address, phone number, username and password, job title and survey responses
  Commercial Information	Products and services purchased, obtained, or considered and other purchasing or consuming histories or tendencies, as well as information about what of our Swoop Services materials you viewed or consumed while visiting our website
  Geolocation Data (Non-Precise)	Based on information contained on your browser when you visit our website

   

  Please Note: Information collected through or in connection with your visiting or viewing our website is not used in connection with our creation or provision of the Swoop Services.

  (B) Events and Marketing

  When you register to attend a Swoop-sponsored event, such as a speaking engagement, industry event, live promotional event, or when you subscribe to our publications or ask for additional information about the Swoop Services, we collect the following types of personal information.

  Category of Information	Description
  Identifiers/Biographical Information	This information may include name, postal and email address, company information and job title, and phone number, or other information requested when registering for our events or product information.
  Device and Usage	If you are registering for an event online or to attend a virtual event, we may collect information such as device identifiers, Internet Protocol (“IP”) address, and other similar identifiers, cookie records, browser type, internet service provider (ISP), device IP address, operating systems and versions, advertising identifiers, device motion data, web beacons and clickstream data.
  Attendance	If you attend an in-person Swoop-sponsored event, we may collect information about the events you attend and how you engage with us and other event sponsors during the event. We may also take video recordings and photographs during the event that may include your likeness.
  Travel Accommodations	For in-person events, we may elect to assist with your travel arrangements, in which case we would collect information from you to enable us to provide this assistance, such as government-issued I.D. information, airline and flight information, lodging and dates of travel, or non-precise information about the region in which you are located or travel to for purposes of attending the relevant Swoop-sponsored event.
  Commercial Information	We may collect information about which Swoop Services or products you or your business purchased, obtained, or considered, as well as other purchasing or consuming histories or tendencies.
  Inferences	Meaning inferences drawn from the above-listed categories to create a consumer profile reflecting consumer preferences or characteristics

   

  Please Note: Information collected in connection with your registration to attend a Swoop-sponsored event or to receive marketing materials or products and services information from us is not used in connection with our creation or provision of the Swoop Services.

  (C) Business Contacts.

  If you are a representative of one of our existing or potential business customers or suppliers, we collect the following types of information about you.

  Category of Information	Description
  Professional Identity and Contact Information	Including name, postal and email address, company information and job title, professional social media sites (e.g., LinkedIn) and phone number
  Transactional Information	If you purchase any of the Swoop Services on behalf of your business, we collect information such as your credit or debit card number or other information relating to the business transaction, including certain categories that fall within the California Customer Records statute
  Commercial Information	We may collect information about which Swoop Services or products you or your business purchased, obtained, or considered, as well as other purchasing or consuming histories or tendencies
  Geolocation Information (non-precise)	We may collect geographical information about which region you are located in or travel to on behalf of your business, industry events that you attend, or public forums that you participate in, including information you make available in those places
  Inferences	Meaning inferences drawn from the above-listed categories to create a business representative or business consumer profile reflecting your or your business’s preferences or characteristics

   

  Please Note:  Information collected in connection with your status as a representative of one of our business clients or providers is not used in connection with our creation or provision of the Swoop Services.

  (D) Swoop Services.

  As part of our health care professional and health care industry marketing products, we may collect the following information and data related to the professional identities and professional activities of healthcare providers and other healthcare industry professionals.

  Category of Information	Description
  Professional Identity and Contact Information	Including name, postal and email address, company information and job title, professional social media sites (e.g., LinkedIn) and phone number, and other identifiers, such as National Provider Identifier, device identifiers, Internet Protocol (“IP”) address, and other similar identifiers.
  Professional Activity	Information about your professional activity such as your specialty, educational background, references, contributions to events, participation in clinical trials, publications and publicly available collaborations between you and other professionals or companies in the healthcare industry We may also collect publicly available professional social media information related to you, such as hyperlinks to professional network sites, publicly posted content, social media handles, public tweets, hashtags, likes, followers and mentions
  Commercial Information	We may collect information about which Swoop Services or products you or your business purchased, obtained, or considered, as well as other purchasing or consuming histories or tendencies
  Geolocation Information (non-precise)	We may collect geographical information about which region you are located in or travel to on behalf of your business, industry events that you attend, or public forums that you participate in, including information you make available in those places
  Inferences	Meaning inferences drawn from the above-listed categories, such as such as your professional interests and professional engagement preferences

   

  We may combine personal information that we receive from various sources. For example, we may combine personal information that we receive from our business customers (e.g., a list of NPIs that the business customer would like to market to), with personal information we already have (e.g., Device Identifier information). We use, disclose, and protect combined personal information as described in this Privacy Statement.
  
  We do not collect information from consumers directly as part of our consumer marketing data products. Instead, we license the use of certain information   from reputable third-party data providers who maintain databases of information about adult consumers in the United States. This information is tokenized and anonymized prior to accepting it into our technical systems in order to ensure that we don’t have pieces of information in our environment that we could use to directly identify any individual. Such information may include the following.

  Category of Information	Description
  Demographic Information	Including age or age range, gender, education level, state-level geography, general income range, or other demographics that describe general categories of groups of individuals

   

  Please Note: We also license and process health-related information that has been certified by a qualified expert to meet the de-identification standards and requirements set out in the federal health privacy law, entitled the Health Insurance Portability and Accountability Act (HIPAA). De-identified health-related information is no longer protected health information (PHI) under HIPAA, nor personal information subject to this Privacy Statement. We do not re-identify or attempt to re-identify any data which has been de-identified.

  (E) For California Residents. NOTICE AT COLLECTION:

  The categories of personal information we collect include:

  • Identifiers/biographical information, including name, postal and email address, company information and job title, and phone number. Also, other identifiers, such as National Provider Identifier, device identifiers, Internet Protocol (“IP”) address, and other similar identifiers.
  • Personal Data categories listed in the California Customer Records statute, such as a representative of a business’s credit or debit card number or financial account information for the purpose of procuring Swoop’s Services.
  • Characteristics of protected classifications under California or Federal law.
  • Commercial information, including products and services purchased, obtained, or considered and other purchasing or consuming histories or tendencies.
  • Internet or other electronic network activity information
  • Audio, electronic, visual, thermal, olfactory, or similar information
  • Inferences, meaning inferences drawn from the above-listed categories of Personal Data to create a consumer profile reflecting consumer preferences or characteristics.

  
  We collect this information to fulfill the purposes outlined in “The Business and Commercial Purposes for which we Collect and Use your Information” section of this privacy note. The sources of this information are detailed in the “How we collect Information” section. We may share the collected information as described in the “How we Disclose or Share your Information” section, including the purposes for disclosure and the categories of recipients.  

  We may sell or disclose certain identifiers and biographical information to our partners, including service providers, research/analytics partners, and marketing/advertising vendors.

  We do not knowingly collect, use, sell or share Personal Data about persons under the age of 18.

  Please click here to submit a request to exercise your privacy rights, including to opt out of the sale or sharing of your Personal Data.  You may also choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). Where available, we will process the GPC signal as a request to opt out.

• HOW WE COLLECT INFORMATION

  There are several sources from which Swoop may obtain information that identifies you, directly or indirectly, including from (A) information you provide to us; (B) information we automatically collect via data collection technologies; (C) information we receive from third parties; and (D) combining information from different sources.  Swoop utilizes a variety of methods to collect this information, including using different data collection technologies, such as cookies, pixels, and tags, on our website, or in email messages and advertisements we serve.  Please note that these data collection technologies may also be placed by third parties, the providers of which may create one or more identifiers associated with you or your device(s).  As indicated above, this Privacy Statement does not cover collection or use activities of third parties. 
  

  For information on choices you may have with respect to these data collection technologies see the “Your Privacy Rights and Choices” section below.

  (A) Information You Provide.

  • Via Our Website. We collect personal information using data collection technologies when you visit our website and request information about the Swoop Services or other materials and information we may provide – e.g., when a prospective customer goes to our website and provides their contact details for further information about one of our applicable products or services.
  • When You Make a Purchase. If you purchase Swoop Services from us, we or our third-party vendors may collect payment and/or other financial information directly from you in order to process the transaction(s).
  • Swoop Events and Marketing. If you register to attend a Swoop-sponsored event or sign up to receive our publications, newsletters or other information, we collect your information directly from you as needed to administer your participation in Swoop events or to ensure the receipt of the requested marketing or other informational materials.  We may also collect information about you, your employer or your business from publicly available sources such as LinkedIn or your employer’s or business’s website.

  
  For information on choices you may have with respect to these data collection technologies see the “Your Privacy Rights and Choices” section below.

  (B) Data We Automatically Collect.  We and our third-party partners and service providers may use a variety of technologies to automatically collect certain data when you are engaging with our website or other Swoop Services, including:

  • Device and Browser Information – this includes your device’s IP address and/or other unique identifiers, cookies, browser type, device type, internet service provider, and operating system.
  • Non-Precise Location Information – This includes your device’s approximate location (derived from your device’s IP address or other signals).
  • Usage Information – This includes certain information about use of our website and products and services, including the date and time of your visit, the pages you view immediately before and after you access our website, as well as how you engage with our business customer tools, or information related to how are products and services are performing.  It may also include keystrokes, mouse movements, form field entries, recordings of chat sessions or your use of and inputs to other AI-supported tools, and other use and overall engagement with our website, products, and services.
  • Marketing Information – This includes, for example, if you receive an email from us, information may be collected about your interactions with the message (e.g., whether you opened, forwarded, or clicked through to our website) or, if you are a HCP and you receive an ad served in connection with our services, we may receive analytic data regarding your engagement with that ad.
  • Third-Party Analytics Technologies – This includes how our website and the Swoop Services are being used, and how to improve their effectiveness as well as the effectiveness of any related content.

  
  For information on choices you may have with respect to these data collection technologies see the “Your Privacy Rights and Choices” section below.

  (C) Third Party Data. We may receive personal information from third-party sources, including:

  • Our Business Partners and Suppliers – This Includes companies that license data to us about HCPs or demographic data about consumers in connection with our creation and provision of the Swoop Services.
  • Our Marketing and Analytics Partners – Including online advertising networks and analytics providers that provide data related to our marketing and advertising activities.

  
  (D) Combination of Data. We may combine personal information that we receive from various sources. For example, we may combine personal information we’ve licensed from a third party about an HCP with other personal information or data we already have or directly collected about that HCP.  We use, disclose, and protect combined personal information as described in this Privacy Statement.

  (E) Swoop Services. As part of our HCP marketing and data products, we directly collect information about healthcare providers and other professionals in the healthcare industry from publicly available sources, including government maintained license and information databases, industry association events and websites, websites maintained by healthcare industry institutions such as schools, hospitals, research institutions and programs, and other publicly available sources of information on industry professionals, such as publicly accessible LinkedIn profiles.  We may also license personal information related to these professionals, organizations and institutions from third parties.  With respect to our consumer marketing and data products, we don’t directly collect your personal information, but instead license de-identified or anonymized information from trusted and reputable third-party data aggregators. 
  

  Swoop’s Services and our website, events and marketing activities are all designed for a U.S. business audience.  Our website and the Swoop Services are not designed or directed towards anyone under the age of 18.  We do not knowingly collect, sell or share personal information about persons under the age of 18 as part of Swoop Services.  If you believe we have inadvertently collected or processed the personal information of anyone under the age of 18, please contact us promptly using the methods described in the “How To Contact Us”  section of this Privacy Statement so that we can investigate and take any actions necessary to correct the issue.

• THE BUSINESS AND COMMERCIAL PURPOSES FOR WHICH WE COLLECT AND USE YOUR INFORMATION

  (A) Maintenance and Provision of the Website, Products, and Services – To provide, operate, and maintain our website and applicable products and services (such as our products and services that enable business customers to market to HCPs).  To conduct analytics and other internal research to develop and improve our website and applicable products and services, including through the use of keystrokes, mouse movements, form field entries, recordings of chat sessions, or your use of and inputs to other AI-supported tools.  To conduct analysis and develop new products and services.

  (B) Communication, Marketing, and Advertising – To engage in customer support, maintain our customer relationships, and to otherwise respond to requests.  To deliver customized content on our website or elsewhere (e.g., through Webinars) in related to our applicable products and services.  To send information, newsletters, targeted offers, and other marketing/advertising material from us and or our marketing partners and affiliates on our website and elsewhere (e.g., on other websites) and to analyze the performance of these activities.

  (C) Safety, Compliance, and Legal – To monitor, protect, and maintain the security and integrity of our website, applicable products and services, and our business, such as protecting against and preventing fraud, unauthorized transactions, claims, and other liabilities. To comply with applicable laws and regulations and respond to lawful requests and communications from law enforcement and other government officials. To carry out sales and business transactions in which information held by us is among the assets transferred or is otherwise relevant to the evaluation, negotiation, or completion of the transaction. To protect our rights, privacy, safety, property and/or those of others.

• HOW WE DISCLOSE OR SHARE YOUR INFORMATION

  We may disclose each category of your personal information that we collect to the following categories of recipients outlined below.  Please note that we may de-identify or aggregate personal information or combine it with other data so that it will no longer be considered personal information and disclose such data to other parties for purposes consistent with those described in this Privacy Statement.  You can find more information about Swoop’s Services here, and information about how to exercise your rights below in the “Your Privacy Rights and Choices” section of this Privacy Statement.

  • Our Service Providers – We may disclose your personal information to our service providers that provide business, professional, or technical support services to us, help us operate our business (including our website and the Swoop Services), or administer activities on our behalf.  We require our service providers to use your personal information in connection with providing services to Swoop.
  • Our Research/Analytic Partners – we may disclose your personal information to our research and analytics partners, including those that administer surveys or conduct research projects in partnership with us or on our behalf or help us to analyze data we collect and use in connection with operating our website and providing Swoop’s Services (e.g., partners that measure and assess advertisements we send to HCPs).
  • Marketing and Advertising Vendors – we may also disclose personal information to marketing vendors in connection with our business and to support our website and Swoop’s Services as described in this Policy.  They help us serve advertisements across the internet, including on mobile, desktop and connected television devices, as well as deliver marketing to prospective business customers.  They also assist with measuring the effectiveness of such marketing and advertising efforts.  For example, we may share personal information of HCPs with our marketing vendors to assist us in serving an ad for our business customer.
  • Competent Government, Regulatory, and Public Authorities – we may disclose your personal information to government and law enforcement authorities, in each case to comply with legal or regulatory obligations or requests.
  • Relevant Third Parties as Part of a Corporate Transaction – in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), we may disclose or transfer your personal information to certain third parties, such as the acquiring entity and its advisers.
  • Other Third Parties – we will disclose your personal information to other third parties at your direction or with your consent. Additionally, we will disclose your personal information as we believe necessary or appropriate to: (a) comply with applicable law; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety, or property, and/or those of you or others; and (e) allow us to pursue available remedies or limit damages that we may sustain.  We may also disclose your personal information for other reasons that we will describe at the time of information collection or prior to disclosing your information to another party.

• YOUR PRIVACY RIGHTS AND CHOICES

  You have the ability to make certain choices about how your personal information is processed. 
  

  Please note that these rights do not apply to data processed through Swoop’s Services that is not personal information as defined in applicable laws (e.g., data that has been de-identified or that is publicly available is not “personal information” for purposes of applicable consumer privacy protection laws).  You can find more detailed information about Swoop’s Services and its use of such de-identified data here.
  

  Your Privacy Rights
  Depending on your U.S. state of residence, including California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, Virginia, and such other states with privacy laws that are enacted, you may have certain rights in relation to your personal information, including those listed below.

  If you are interested in exercising one or more of the rights outlined below, you can do any of the following:

  • Click here;
  • Email us at privacyrights@swoop.com (please put the statement “Your Privacy Rights” in the subject field of your email);
  • Contact us by U.S. postal mail by sending a communication to 228 Park Ave S PMB 924225, New York, NY 10003, ATTN: PRIVACY OFFICER;
  • Or follow any specific instruction set forth below.

  
  In order to process your privacy rights request, we require you to provide certain information about yourself. We will only use this information to verify your identity and facilitate the processing of your request. For some rights, we may take reasonable steps to verify your identity before responding to your requests, including, for example by asking you to provide documentation or answering a series of questions about your engagement with us (e.g., time and manner by which you completed a form requesting more information on Swoop’s Services).  Submitting a privacy rights request does not require you to create an account or register with us.

  Please note that, where permitted under applicable law, we may decline a request (other than for opt outs) if we are unable to verify your identity (or an agent’s authority to make the request on your behalf) and confirm the personal information we maintain relates to you.  We will not discriminate against you if you decide to exercise your privacy rights.

  Right to Know
  You may have the right to know what personal information we have collected about you, including the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, the categories of personal information disclosed to third parties, and the specific pieces of personal information we have collected about you. Please note that we may not be required to respond to your requests “to know” or access specific pieces of personal information more than twice in any 12-month period.

  Right to Request List of Categories of Third Parties
  You may have the right to request a list of the categories of third parties to which we have disclosed personal data.

  Right to Request Specific List of Third Parties
  You may have the right to request a list of the specific third parties with which we have shared or sold personal information.

  Right to Data Portability 
  You may have the right to access your personal information in a portable format.

  Right to Delete
  You may have the right to request that we delete personal information that we have collected from or about you, subject to certain exceptions.

  Right to Correct
  You may have the right to correct inaccurate personal information that we may maintain about you, subject to appropriate verification.

  Right to Opt-Out
  You may have the right to opt out of the “Sale” or "Sharing” of your personal information, or the use of your personal information for “Targeted Advertising” (as these terms are defined in applicable law).  For example, you may have the right to opt-out of our disclosure of your personal information to third parties for analytics and advertising purposes.

  To opt out of the Sale or Sharing of your personal information, or use of your personal information for Targeted Advertising, use the methods described above in the section entitled “Your Privacy Rights,” or click on the “Your Privacy Choices” link here or at the bottom of our website homepage.

  Depending on the internet browser you are using (e.g., Firefox or Safari), you may also be able to use certain preference signals to exercise your opt-out right automatically with all businesses that you interact with online, including Swoop.  If you enable a browser-based opt-out preference signal, such as Global Privacy Control (GPC), Swoop endeavors to receive or detect such preference signal and will treat the signal as a request to opt out of the Sale or Sharing of personal information or use of your personal information for Targeted Advertising. If you use different browsers, you may need to enable the signal on each browser. 
  

  Please note: to date, no commonly accepted industry standard for browser-based GPCs has been adopted by businesses or regulators, which means that Swoop may not currently receive or detect these signals consistently or with complete accuracy. We continue to develop our capabilities and work with our legal, privacy and technical professionals to implement measures to accurately honor GPC signals.  If for some reason we have not been able to detect a GPC that you have activated, please also ensure to submit your privacy rights request to us via the methods described above in the section entitled “Your Privacy Rights,” or click on the “Your Privacy Choices” link here or at the bottom of our website homepage.

• YOUR ADDITIONAL MARKETING AND ADVERTISING CHOICES

  Email Marketing
  From time to time, we may send you marketing and promotional communications, including special offers from us or our partners. If you no longer wish to receive promotional and marketing emails from us, you may opt out of such communications at any time by following the opt-out instructions included in any promotional or marketing email you receive from us.

  Interest Based Advertising; Industry Self-Regulatory Tools
  In addition to the opt-out Swoop provides, you may be able to opt out of receiving certain interest-based advertisements using available browser and device opt-out tools and consumer choice mechanisms provided by advertising industry self-regulatory groups that Swoop participates in, such as the NAI or the DAA.  You can opt-out of interest-based advertising by following the instructions found on the NAI’s Consumer Opt Out Website located at https://optout.networkadvertising.org/.  You can also use the DAA’s WebChoices tool to opt-out using the instructions found on their website located at https://optout.aboutads.info/.

  You may need to exercise the choices offered through your devices and by industry self-regulatory groups separately on all of your browsers and devices, as each opt out may apply only to the specific browser or device from which you opt out.  If you delete or reset your cookies or mobile identifiers, change browsers, or use a different device, any opt-out cookie or tool may no longer work, and you will have to opt out again.

  These choices are designed to enable you to control the advertising you see off Swoop’s website and outside of the products and services Swoop controls.  Even if you choose to opt out of receiving interest-based advertising, you may still receive advertising, but the advertisements may be less relevant.

  These choices are in addition to the opt-out right Swoop offers directly and is described above.  You do not need to exercise any of these opt-out choices to stop Swoop’s Selling, Sharing, or Targeted Advertising (as these terms are defined by applicable law).

  Web browsers
  Your web browser may offer various privacy choices related to advertising.  For example, you may be able to delete your browsing data and third-party cookies, control the information that websites can access from and about you through your browser (e.g., your location and camera), and configure settings to limit browser data that can be used to show you ads.  These choices may be accessed through the setting menu of your browser.

  Mobile and Living Room Devices
  Your device operating system may also provide choices that allow you to control the use of information for advertising purposes.  For example, your mobile device may allow you to restrict the data that can be collected and used through your device (e.g., location, contacts), to restrict the ability of applications on your device from collecting and using data about you to deliver interest-based advertising and permit you to turn off personalized advertising by the operating system provider.  These choices may be accessed through the settings menu of your device.

  Social Media
  Social media platforms allow you to control your advertising preferences directly through their services.  Please review the privacy policies of the specific social media services you use for more information.

  Industry Self-Regulatory Tools
  Network Advertising Initiative (NAI): Swoop is a member of the NAI and integrated with the NAI’s advertising tool.  You can find more information about the NAI’s tool and opt-out of interest based online ads from NAI members, including Swoop, here (https://optout.networkadvertising.org/).

  Digital Advertising Alliance (DAA): Swoop is also a member of the DAA and integrated with the DAA’s advertising tool.  You can find more information about the DAA’s tool and opt-out of interest based online ads from DAA members, including Swoop here (https://youradchoices.com/control).

  Agent Requests
  Only you, or someone legally authorized to act on your behalf, may submit a request related to your personal information as described in this Policy.

  Depending on your U.S. state of residence, you may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf.  Swoop retains the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity, including documentation such as an Authorized Agent Form or Power of Attorney.

  Right to Appeal
  Depending on your U.S. state of residence, you may have the right to appeal a decision we have made in connection with your privacy rights request. To appeal a decision, please contact us at privacy@swoop.com.

• CHILDREN’S PRIVACY

  Our website, products, and services are intended for a general audience. We do not direct our website, products, or any of Swoop’s Services to individuals under eighteen (18), nor do we knowingly solicit or collect any personal information from individuals under eighteen.

• DATA SECURITY

  We have implemented physical, administrative, and technical safeguards to maintain the security, confidentiality, and integrity of your information. However, as no transmission of information over the internet is absolutely secure, we cannot guarantee the safety of your information.

• REVISIONS TO THIS PRIVACY STATEMENT

  We reserve the right, in our sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Statement at any time.  When we do, we will post the change(s) to our website.  Your continued use of our website following the posting of changes to these terms means you accept these changes.  If we change the Privacy Statement in a material way, we will provide appropriate notice to you and seek your consent where required by applicable privacy laws. Such notice may be provided via a temporary banner on our website, an email sent to our business customers for whom we have an email address, or by temporarily noting “UPDATED” next to the Privacy Statement link on the footer of our website.

• HOW TO CONTACT US

  If you have any questions or concerns about this Privacy Statement or the practices described herein, you may contact us at privacyrights@swoop.com or by mail to 228 Park Ave S PMB 924225, New York, NY 10003, ATTN: PRIVACY OFFICER.