Last updated and effective on: January 2024

Introduction

SWAF (“Company,” “we,” or “our”) respects and values your privacy. This Notice describes our practices with respect to how we process your personal information. It explains the types of information we may collect about you when you interact with this website (our “Website”) and how we may collect, use, maintain, and disclose your personal information and our practices for protecting it. This Notice solely applies to this Website. It does not apply to any third-party websites, including through any application or content that may link to, or be accessible from or through, the Website.

Please read this Notice carefully to understand our policies and practices regarding your personal information and how we will treat it. By accessing or using this Website, you acknowledge that you have read and understand this Notice. We may update this Notice from time to time. We will notify you as described in the “Changes to Our Privacy Notice” section of this Notice. Otherwise, please continue to check this notice periodically for updates. Your continued use of this Website after we make changes is deemed to be an acknowledgment that you have read and understand  those changes. We may be contacted using the information provided in the “Contact Us” section of this Notice if you have any questions. 

  • AGE RESTRICTION. THE WEBSITE IS INTENDED ONLY FOR USERS WHO ARE 21 AND OLDER. Our Website is not directed to or intended for users who are under 21 years of age. No one under 21 may provide personal information to or on the Website. We do not knowingly collect personal information from users under 21. If you are under 21, under no circumstances may you use this Website or submit any information on this Website or provide any information about yourself to us.
  • UNITED STATES ONLY. THIS WEBSITE IS INTENDED ONLY FOR USERS IN THE UNITED STATES. This Website is hosted in the United States and data collection through the Website will be stored and processed in the United States.     

Information We Collect About You and How We Collect It

Information We Collect Directly From You

We collect the following categories of personal information directly from you: 

  • your age when you provide it to us to establish that you are of legal age to use the Website,
  • your email address when you sign up for emails from us or our newsletter,
  • your information when necessary to request feedback and to contact you about your use of the Website,
  • information that you provide when you report a problem with our Website or exercise a rights request, and 
  • information when you RSVP for an event, participate in surveys or questionnaires, or contests, sweepstakes or other promotions made available through the Website. 

Information We Collect From Others About You 

We may also collect personal information about you from our business partners and other third parties, including data analytics providers, marketing and advertising service providers, social media platforms and networks, and fraud prevention service providers. 

Information We Collect Through Automatic Data Collection Technologies  

We use automated tracking technologies, such as cookies and web beacons, to collect information about you when you use the Website. Cookies are small files placed on the hard drive of your computer. Web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) are small electronic files that permit us, for example, to count users who visited certain pages on our Website and other related statistics. For the purpose of this Notice, we refer to cookies and similar tracking technologies as “cookies” from here on. Generally, we use the following categories of cookies:

  • functional cookies that enable the Website to provide enhanced functionality, certain user experiences and personalization. Some or all Website functionalities may be impaired if you do not allow these cookies.
  • performance cookies that support analytic services to help us improve the Website’s functionality and user experience.
  • advertising cookies that allow us to personalize content and advertising to you on our own and other websites. 

We may use cookies to collect information about your equipment, browsing actions, and patterns when you use our Website. This information may include details about your visits to our Website and information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use cookies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically helps us to improve our Website and for marketing and advertising purposes. 

Our use of tracking technologies includes cookies used for Google Analytics, which collects information on how users use our Website. For more information on Google Analytics, please visit  “How Google uses information from sites or apps that use our services.”

For more information about how you can adjust your cookie settings, click here. You may also read more information about how you can adjust your cookie settings in the “Choices About How We Use and Disclose Your Information” section.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you and to customize your experience.
  • To establish that you are of legal age to use the Website. 
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide the information.
  • To notify you about changes to our Website or any of our products or services.
  • To analyze, manage, and improve the Website and our services and enhance our ability to provide relevant marketing regarding our products and services.  
  • To diagnose problems or technical errors with the Website. 
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We also use your information for the purposes described in “How We Use Your Personal Information” section in the California Consumer Privacy Act Addendum.

Disclosure of Your Information

We may disclose aggregated or deidentified information about our users, and information that does not identify any individual, without restriction. 

We may disclose personal information that we collect or you provide as described in this Notice:

  • To our subsidiaries and affiliates.
  • To vendors, distributors, contractors, service providers, and other third parties we use to perform services on our behalf and require that information to do that work and to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To protect the Website and our services, including, without limitation, to enforce or apply our Terms of Use.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
  • Emails from the Company. If you do not wish to have your personal information used by the Company to send you promotional emails to promote our own or third parties’ products or services, you can opt-out from those promotional emails by using the unsubscribe link in the email that you receive.

Residents of certain states may have additional personal information rights and choices. Please see the “Your State Privacy Rights” section of this Notice for more information.

California Consumer Privacy Act Addendum

If you are a California consumer, the following provisions apply to our processing of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“California Personal Information”). For California consumers, the provisions of this Addendum prevail over any conflicting provisions in other sections of this Notice.

California Personal Information We Collect About You and How We Collect It

We collect, and in the last 12 months have collected, the following categories of California Personal Information:

  • Identifiers such as Internet Protocol address, email address, and date of birth.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, and information regarding a consumer’s interaction with an internet website application, or advertisement.
  • Geolocation data.

We collect this information directly from you when you provide to us or through automatically using cookies and other tracking technologies when you use the Website. Please see “Information We Collect About You and How We Collect It” to learn more about the categories of personal information that we collect and the sources from which we collect it. We retain each category of California Personal Information as described in the “Data Retention” section of the Notice.

How We use Your California Personal Information

For each of the above categories, we use the California Personal Information for a variety of business purposes such as:

  • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  • Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business.
  • Performing services on behalf of the business, including providing analytic services.
  • Providing advertising and marketing services.
  • Undertaking internal research for technological development and demonstration.

Please see the “How We Use Your Information” section of this Notice for additional purposes for which we may use information. We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the California Personal Information was collected.

Disclosure of Your California Personal Information

Within the last 12 months, we have disclosed substantially all categories of California Personal Information to our affiliates and our service providers for our business purposes. To learn more about the categories of third parties with whom we share such information, please see the “How We Disclose Your Information” section of this Notice.

We share, and in the past 12 months have shared, substantially all categories of California Personal Information with our marketing and advertising partners. Otherwise, we do not sell, and in the past 12 months we have not sold, California Personal Information. Additionally, we do not sell or share, and in the past 12 months we have not sold or shared, California Personal Information of individuals we know to be under 16 years of age.

We do not collect nor disclose sensitive personal information as defined under California privacy law.

Your California Privacy Rights

If you are a California consumer, you have certain rights related to your California Personal Information, including:

  • The Right to know what California Personal Information we have collected about you, including the categories of California Personal Information, the categories of sources from which the California Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing California Personal Information, the categories of third parties to whom we disclose California Personal Information, and the specific pieces of California Personal Information we have collected about you.
  • The right to delete California Personal Information that we have collected from you.
  • The right to correct inaccurate California Personal Information that we maintain about you.
  • The right to opt out of the sale or the sharing of California Personal Information.
  • The right to limit the use or disclosure of your sensitive California Personal information.
    • We do not use or disclose sensitive personal information for purposes that, under applicable law, require us to support the right to limit the use or disclosure of sensitive personal information.
  • The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by applicable law, including the right not to be retaliated against for the exercise of your rights.

You may request to exercise these rights by:

  • Emailing us at [email protected];
  • Calling us at [INSERT NUMBER]; or
  • Completing our privacy rights request form here.

As required under applicable law, we will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide your first name, last name, and email address to verify your identity in response to exercising requests of the above type. We may limit our response to your exercise of the above rights as permitted under applicable law. When you submit a request to exercise your rights above, we will use the information you provide to process your request and to maintain a record of your request and our response, as permitted under applicable law.

Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the agent to provide proof of that written permission. To the extent permitted by law, we may require you to verify your own identity in response to a request, even if you choose to use an agent. 

If you are an authorized agent submitting a request on behalf of a California consumer, please complete our privacy rights request form available here.

California Do Not Track

California residents are entitled to know how we respond to “Do Not Track” browser settings. We do not currently take actions to respond to Do Not Track signals. However, we process opt-out preference signals as required by applicable law.

Your State Privacy Rights

State consumer privacy laws may provide their residents with the following additional rights regarding our use of their personal information:

  • The right to confirm whether we process personal information about you and request access to such personal information (including, if applicable, in a portable and readily usable format).  
  • The right to correct inaccuracies in certain personal information we may hold about you; and
  • The right to request that we delete personal information collected about you.
  • The right to opt out of the processing of personal data for the purposes of (i) targeted advertising, (ii) the sale of personal information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
    • We do not process personal information for purposes that, under applicable law, require us to support the right to opt out of the sale of personal information or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • The right to appeal our decision regarding your rights request.
  • The right to not be discriminated against for the exercise of your state privacy rights.

You may request to exercise these rights by:

If you are an authorized agent submitting a request on behalf of a consumer, please complete our privacy rights request form available here.

Please note that we do not collect personal data revealing racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or citizenship status; genetic or biometric data; or personal data from consumers who we know are under 13 years of age.

Data Security

We implement reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. However, we cannot guarantee the security of your personal information because the transmission of information over the internet is not completely secure. Further, we are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Data Retention

We retain personal information for the length of time necessary to carry out the processing purposes described in this Notice. We also retain information for related business purposes, security, legal compliance, and disputes, consistent with our retention policy and as permitted by applicable law.

Changes to Our Privacy Policy

It is our policy to post any changes we make to this Notice on this page. If we make material changes to this Notice, we will notify you by email to the email address specified if you have signed up for our newsletter. The date this Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Notice to check for any changes.

Contact Information

To ask questions or comment about this Notice and our privacy practices, contact us at: 

[email protected] or via our toll-free number (844) 926-6033.

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